The Central Bank of Brazil (BACEN) published, on 11/10/2025, Resolutions No. 519, 520, and 521, establishing the awaited BACEN’s framework for virtual assets. This measure consolidates the regulatory framework applicable to virtual asset service providers (VASPs) and virtual asset service provider companies (VASPCs).
These rules complement and align with the Virtual Asset Legal Framework (Law No. 14,478/2022) and Decree No. 11,563/2023, with a focus on market integrity, customer protection, anti–money laundering and counter–terrorist financing (AML/CFT), governance, asset segregation, and cybersecurity. The effective dates are set for February 2, 2026, with specific timelines for authorization, operational adaptation, purpose classification and regulatory reporting, and prohibitions on transactions with non-authorized providers as of October 30, 2026. The set of rules establishes authorization processes, formation and operating requirements, and discipline participation in the foreign exchange market, advancing convergence with international best practices.
Authorization processes for SPSAVs to operate (Resolution No. 519)
Resolution No. 519 defines SPSAVs and provides that intermediation, brokerage, and custody of virtual assets in Brazil require prior authorization from BACEN. SPSAVs are subject to obligations equivalent to those of financial institutions, including transparency in client relationships, AML/CFT policies and controls, governance requirements, risk management, and information security. For companies already operating as of the effective date, the authorization process will proceed in two phases. In the first phase, BACEN will verify the existence and nature of activities under Law No. 14,478/2022, as well as the conformity of corporate structure, controlling shareholders, and holders of qualifying stakes, and may request audited financial statements. In the second phase, Bacen will assess compliance with the remaining regulatory requirements, with the possibility of documentary updates to ensure continuing satisfaction of the conditions required. The phased approach is intended to provide an orderly and safe transition for incumbent firms, reinforcing market credibility and investor protection.
Formation, operation, and supervision of PSAVs/SPSAVs (Resolution No. 520)
Resolution No. 520 governs the formation, operation, and supervision of PSAVs/SPSAVs, defining the service modalities (intermediation, custody, and brokerage) and delimiting each scope of activity. The rule requires segregation of client assets from firm assets, robust cybersecurity standards and internal controls, rules for selecting and disclosing information about virtual assets, and policies to mitigate conflicts of interest. It sets forth fee transparency requirements, specific responsibilities for transactions and custody, independent audits, and proof-of-reserves mechanisms, in addition to risk-proportionate AML/CFT policies and procedures. The text addresses eligible financial institutions, defines authorization processes and transition timelines for entities already in operation, and, as of October 30, 2026, prohibits dealings with non-authorized providers. It also provides an implementation schedule for domestic and international information exchange through February 2, 2028, aiming to reduce operational and systemic risks and to protect clients.
Inclusion of PSAV activities in the Foreign Exchange Market (Resolution No. 521)
Resolution No. 521 integrates operations with virtual assets into the framework of Law No. 14,286/2021, regulating the participation of PSAVs in the foreign exchange market. Measures include prohibiting the use of cash and the purchase and sale of virtual assets with payment or receipt in foreign currency, as well as prohibiting the movement of funds in third parties’ benefit outside of authorized institutions. Limits are set per transaction with non-authorized counterparties, with distinct ceilings for non-bank institutions authorized to operate in foreign exchange and for PSAVs. The Resolution imposes enhanced AML/CFT controls, including identification of owners of self-hosted wallets, verification of the origin and destination of crypto assets, and diligence on foreign PSAVs. It defines standardized purpose classifications, client data collection, and monthly reporting obligations to BACEN by the 5th business day, covering international transactions involving virtual assets, transfers linked to cards or international payment instruments, interactions with self-hosted wallets, and volumes of purchase, sale, and exchange of crypto assets referenced in fiat currency.
It further integrates virtual asset transactions into the rules on external credit, foreign direct investment, and Brazilian capital abroad, requiring authorization, minimum capital, governance, and infrastructure commensurate with the activity, with effective schedule starting February 2, 2026, and reporting obligations effective as of May 4, 2026.
