São Paulo/New York - 25 February 2026

Notabene, Veirano Advogados and ABToken announced today the launch of the Brazil Virtual Asset Regulatory Playbook, a practical implementation guide designed to help institutions navigate Brazil’s new regulatory framework for virtual asset service providers, including licensing, operational, AML/CFT obligations and Travel Rule requirements.

With the Central Bank of Brazil’s (BCB) new rules for virtual asset service providers (VASPs) now in force, Brazil enters a new phase of supervised virtual asset activity. The framework established by BCB Resolutions 519, 520, and 521 introduces a comprehensive licensing, supervisory, and AML/CFT regime for VASPs, as defined under Brazilian Law No. 14,478/2022.

Crucially, while Travel Rule obligations will be phased in through 2028, certain foreign exchange (FX) reporting requirements begin much sooner. Under BCB Normative Instruction No. 693, institutions must begin monthly reporting of FX-scoped virtual asset transactions, including self-hosted wallet and cross-border transfers, starting in May 2026. In practice, this means key originator and beneficiary data collection capabilities must be operational well ahead of full Travel Rule enforceability.

Designed for compliance, legal, operations, and product teams, the Brazil Playbook provides detailed guidance on:

• The VASP licensing framework and supervisory timelines;
• A breakdown of Travel Rule obligations under BCB Resolution 520;
• How foreign exchange reporting requirements intersect with Travel Rule controls; including the May 2026 monthly reporting obligation; 
• The requirement for SPSAVs conducting FX-scoped activities to obtain both SPSAV and foreign exchange market licenses; and
• A phased implementation roadmap aligned to 2026 - 2028 enforcement milestones.

The Travel Rule framework under BCB Resolution No. 520 requires SPSAVs to collect, verify, retain, and transmit originator and beneficiary information for all virtual asset transfers, regardless of value. The guide outlines the two-phase rollout of Travel Rule obligations, beginning with domestic transfers between Brazilian VASPs and extending to cross-border transfers by 2028.

“Brazil’s new framework brings clarity, structure, and accountability to the virtual asset market,” said Catarina Veloso, Director of Regulatory & Compliance at Notabene. “The May FX reporting milestone makes it clear that institutions cannot wait until 2027 or 2028 to operationalize Travel Rule capabilities. This Playbook is built to help firms make meaningful progress throughout the two-year phased implementation period, while ensuring they meet interim regulatory milestones along the way.”

“The Central Bank’s regulations represent a structural shift in how virtual asset services are supervised in Brazil”, said Marcos Rocha, Partner at Veirano Advogados. “By clarifying the interaction between licensing, AML/CFT controls, and foreign exchange obligations, we aim to give market participants quick practical guidance.”

“This is a defining moment for Brazil’s virtual asset ecosystem,” said Regina Pedroso, Executive Director at ABToken. “Clear rules and coordinated implementation strengthen trust across the market and position Brazil as a leading jurisdiction for responsible innovation in virtual asset services.”

The Brazil Virtual Asset Regulatory Playbook is available for download now. Download the guide: https://notabene.id/reports/brazil-virtual-asset-regulatory-playbook

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ENDS

About the Contributors

Notabene is the trust layer for global crypto money movement. Our products include Notabene Flow, the first open stablecoin payments platform for businesses, and Notabene Transact, the world's largest Travel Rule-compliant transaction authorization platform for regulated institutions. The Notabene network connects thousands of trusted counterparties, facilitating over $2T in transaction volume annually across more than 100 jurisdictions. It’s built on the Transaction Authorization Protocol (TAP), our open messaging standard that enables verified entities to transact securely. Notabene provides industry-leading tools for stablecoin payment coordination, real-time transaction authorization, counterparty verification, and self-hosted wallet identification—helping institutions build trust into every transaction.

Veirano Advogados is a leading Brazilian law firm with extensive experience advising clients in the fintech and digital assets industries. The firm has been closely involved in some of the most relevant projects in the Brazilian financial and crypto-asset markets, assisting both domestic and international clients on licensing, regulatory structuring, product launches, and complex cross-border transactions. Veirano’s team combines deep knowledge of the Brazilian financial regulatory framework with practical experience in the implementation of compliance programs, providing clients with pragmatic and business-oriented legal solutions in a rapidly evolving regulatory environment.

ABToken is a leading Brazilian industry association created to strengthen the country’s digital asset and tokenization ecosystem. The Association works to promote innovation alongside high standards of governance, regulatory compliance, and market integrity. ABToken represents tokenization platforms, blockchain companies, and virtual asset service providers (VASPs), serving as a unified voice for the sector in its engagement with regulators, policymakers, and market participants, and contributing to the development of a safe, credible, and sustainable digital finance environment in Brazil. 

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