Countries › Brazil › Guide › 13. Regulation › Anti money laundering and sanctions in Brazil: who is an obligated person, KYC and beneficial owners, COAF reporting thresholds and UN asset freezes

Anti money laundering and sanctions in Brazil: who is an obligated person, KYC and beneficial owners, COAF reporting thresholds and UN asset freezes

Argentina. For full detail on Argentina, go to The Argentine Thread.

Last verified: 2026-10-27 · Status: Changing

Banks, payment and virtual asset firms, insurers, real estate developers and brokers, luxury goods dealers and advisers on company and property deals must identify clients and beneficial owners, keep records for at least 5 years and report suspicious activity to COAF. Banks must also report cash operations of R$50,000 or more and, since a September 2026 change, cash FX and self custody crypto transfers of US$10,000 or more. Breaches cost up to twice the transaction or R$20,000,000, and UN Security Council freezes apply in Brazil immediately.

USD figures use the Banco Central do Brasil PTAX selling rate of R$5.3346 per US dollar for 27 October 2026. Conversions are for orientation only.

Key facts

Minimum record retention for AML purposes	5 yearsLei nº 9.613 art. 10 § 2, as of 2012-07-09 · in force
Cash operation size that banks must report to COAF	50000 BRLCircular BCB nº 3.978 art. 49 I and II, as of 2020-01-23 · in force
Advance notice required for cash withdrawals of R$50,000 or more	3 business daysCircular BCB nº 3.978 art. 36, as of 2020-01-23 · in force
Cash FX operation size that must be reported to COAF	10000 USDCircular BCB nº 3.978 art. 49 IV as worded by Resolução BCB nº 591/2026, as of 2026-09-30 · in force
Virtual asset transfer to or from a self hosted wallet that must be reported to COAF	10000 USDCircular BCB nº 3.978 art. 49 V as worded by Resolução BCB nº 591/2026, as of 2026-09-30 · in force
Maximum ownership reference for identifying beneficial owners at banks	25 %Circular BCB nº 3.978 art. 25, as of 2020-01-23 · in force
Maximum prison term for money laundering	10 yearsLei nº 9.613 art. 1, as of 2012-07-09 · in force
Maximum disqualification of managers for AML breaches	10 yearsLei nº 9.613 art. 12 III, as of 2012-07-09 · in force

The rule

1. Concealing or disguising the nature, origin, location, disposition, movement or ownership of assets derived directly or indirectly from any criminal offense is money laundering, punished with 3 to 10 years of imprisonment and a fine; so is converting them into lawful assets, using them in economic activity, or importing or exporting goods at false values. The penalty rises by one to two thirds when committed repeatedly, through a criminal organization or using virtual assets.Lei nº 9.613 of 3 March 1998, as amended by Lei nº 12.683 of 9 July 2012 and Lei nº 14.478 of 21 December 2022, Art. 1 caput and §§ 1, 2 and 4, 2012-07-09 official text · verified 2026-10-27

2. Obligated persons include anyone who, as a main or ancillary activity, raises, intermediates or invests third party funds, trades foreign currency or gold, or handles securities; plus exchanges, insurers and brokers, pension and capitalization entities, card and payment businesses, leasing, factoring and simple credit companies, lotteries and fixed odds betting, branches of foreign entities doing these activities, entities authorized by financial regulators, real estate developers and buyers and sellers of property, dealers in jewels, precious metals, art and antiques, dealers in luxury or high value goods or large cash volumes, commercial registries and public registries, and advisers, consultants, accountants and auditors in deals such as property, business or shareholding purchases and company management.Lei nº 9.613 of 3 March 1998, Art. 9 caput and sole paragraph items I to XIV, 2012-07-09 official text · verified 2026-10-27

3. Obligated persons must identify clients and keep their records updated, including the individuals authorized to represent a corporate client and its owners; keep records of transactions above limits set by the competent authority, including virtual assets; adopt policies, procedures and internal controls proportionate to size; register with their regulator or, without one, with COAF; and answer COAF requests. Records must be kept for at least 5 years from closing the account or completing the transaction.Lei nº 9.613 of 3 March 1998, Art. 10 items I to V and §§ 1 and 2, 2012-07-09 official text · verified 2026-10-27

4. Obligated persons must give special attention to operations that may indicate laundering and report to COAF, within 24 hours and without tipping off anyone, proposed or completed suspicious operations and transactions above the reporting limits. Where no reportable operation occurred, they must make a negative declaration to their regulator or COAF as required. Good faith reports carry no civil or administrative liability.Lei nº 9.613 of 3 March 1998, Art. 11 items I to III and § 2, 2012-07-09 official text · verified 2026-10-27

5. Obligated persons and their managers who breach these duties face a warning; a fine of up to the greatest of twice the transaction, twice the actual or presumed profit, or R$20,000,000; disqualification of managers for up to 10 years; and cancellation or suspension of the authorization to operate.
Cost to do it: Fine up to the greatest of twice the transaction, twice the profit or R$20,000,000.
Example: Failing to report a R$15,000,000 suspicious transfer: twice the transaction is R$30,000,000, which exceeds R$20,000,000, so the ceiling is R$30,000,000. / About US$5,623,664 against a fixed ceiling of about US$3,749,110.Lei nº 9.613 of 3 March 1998, Art. 12 items I to IV and §§ 2 to 4, 2012-07-09 official text · verified 2026-10-27

6. Institutions authorized by the Central Bank must identify the beneficial owner of corporate clients through the ownership chain up to the natural person, using a risk based ownership reference of no more than 25 percent, direct and indirect; a representative with de facto command also counts. PEP status lasts 5 years after leaving office. Monitoring and selection of suspicious operations may take no more than 45 days from the operation, and analysis no more than 45 days from selection; the report to COAF is due by the next business day after the decision to report. Information must be kept available to the Central Bank for 5 or 10 years depending on the item.Circular BCB nº 3.978 of 23 January 2020, Arts. 24, 25, 27 § 5 (PEP), 39, 43 § 1, 48 § 2, 66 and 67, 2020-01-23 official text · verified 2026-10-27

7. Central Bank authorized institutions must report to COAF, by the next business day: cash deposits or withdrawals of R$50,000 or more; payments, receipts and transfers against cash of R$50,000 or more; requests to provision cash withdrawals of R$50,000 or more (which must be requested at least 3 business days ahead); FX operations with delivery or receipt of foreign cash of US$10,000 or more or the equivalent; and transfers of virtual assets to or from self hosted wallets of US$10,000 or more. Reports on the FX and self hosted wallet items for operations between 1 October and 31 December 2026 are due on the first business day of January 2027.
Cost to do it: Reporting systems cost for institutions; no fee.
Example: A customer withdraws R$60,000 in cash: the bank needs 3 business days' notice and reports it to COAF the next business day. / About US$11,247; the cash threshold of R$50,000 is about US$9,373.Circular BCB nº 3.978 of 23 January 2020, art. 49 as worded by Resolução BCB nº 591 of 30 September 2026, Arts. 34 to 36 and 49 items I to V and § 2, 2026-09-30 official text · verified 2026-10-27 · changed: Resolução BCB nº 591 of 30 September 2026 added reports of cash FX operations and self hosted wallet virtual asset transfers of US$10,000 or more, effective on publication, with reports for 1 October to 31 December 2026 due on the first business day of January 2027; it revoked Resolução BCB nº 588 of 23 September 2026.

8. Businesses supervised directly by COAF (those without their own regulator) must adopt AML, counter terrorist financing and counter proliferation policies, procedures and internal controls, including governance, a periodic internal risk assessment, know your customer and know your employee procedures, under Resolução Coaf nº 36, in force since 1 June 2021. Smaller supervised persons may be exempted from some requirements under the parameters of Instrução Normativa Coaf nº 6 of 2021.Resolução Coaf nº 36 of 10 March 2021, Resolution as a whole (governance, internal risk assessment, know your customer and know your employee provisions), 2021-03-10 official text · verified 2026-10-27

9. UN Security Council sanctions resolutions and designations by its sanctions committees are immediately enforceable in Brazil. Obligated persons under Lei nº 9.613 art. 9 must freeze assets of designated persons and entities without delay and without prior notice, and report freezes and attempted transfers to the Ministry of Justice, their regulator and COAF. The Ministry of Justice also relays the measures to registries, aviation, vehicle, port and telecom authorities.Lei nº 13.810 of 8 March 2019, Arts. 6, 9, 10 and 11, 2019-03-08 official text · verified 2026-10-27

Operation	Threshold	Deadline
Cash deposit, contribution or withdrawal	R$50,000 or more	Next business day
Payment, receipt or transfer against cash	R$50,000 or more	Next business day
Request to provision a cash withdrawal	R$50,000 or more	Next business day after provisioning
FX with delivery or receipt of foreign cash	US$10,000 or more or equivalent	Next business day (1 Oct to 31 Dec 2026 operations: first business day of January 2027)
Virtual asset transfer to or from a self hosted wallet	US$10,000 or more	Same as above
Any suspicious operation or situation	No threshold	Next business day after the decision to report

Operations Central Bank authorized institutions report to COAF regardless of suspicion. Source: Circular BCB nº 3.978 art. 49 as worded by Resolução BCB nº 591/2026.

Worked example

Property developer. A foreign owned developer selling apartments in São Paulo is an obligated person (Lei nº 9.613 art. 9 sole paragraph X). It must register with COAF or its supervisor, identify buyers and beneficial owners, keep records for 5 years and report suspicious payments within 24 hours. Missing a report on a R$5,000,000 (about US$937,277) sale exposes it to a fine of up to R$20,000,000 (about US$3,749,110), the greatest of the three caps in art. 12 II.
Crypto exit. A client of a Brazilian bank or virtual asset provider sends US$12,000 of stablecoins to a self hosted wallet in November 2026; the provider must report it to COAF, with reports for the last quarter of 2026 due on the first business day of January 2027 (Resolução BCB nº 591).

Step by step

1. Check whether the Brazilian business falls in Lei nº 9.613 art. 9; advisers in company and property deals and luxury goods sellers are often surprised.
2. Identify the supervisor (Central Bank, CVM, SUSEP, another regulator or COAF) and register.
3. Adopt a written policy, internal risk assessment, KYC with beneficial owner identification and PEP screening, and staff training.
4. Set up monitoring and reporting through COAF's system, including next business day cash and FX reports where applicable and negative declarations where required.
5. Screen clients and counterparties against UN Security Council lists and freeze without delay under Lei nº 13.810.
6. Keep records for at least 5 years (some Central Bank items 10 years).

Common traps

Assuming only banks are covered. Real estate, luxury goods, art, advisory and betting businesses are obligated persons (art. 9).
Tipping off. Reports must be made without informing the client or anyone else (art. 11 II).
Overlooking the new US$10,000 reports. Cash FX and self hosted wallet transfers are reportable since Resolução BCB nº 591 of 30 September 2026.
Waiting for a local order to freeze. UN designations are immediately enforceable in Brazil (Lei nº 13.810 art. 6).
Treating the fine as capped at R$20,000,000. The ceiling is the greatest of twice the transaction, twice the profit or R$20,000,000 (art. 12 II).

Sources

← Anti corruption in Brazil: Clean Company Act liability, fine calculation, integrity programs, leniency and procurement rulesEnvironmental licensing in Brazil: which authority licenses, license types, validity, review deadlines and the 2025 general law →