Brazil has a comprehensive regulatory framework for the crypto market, focusing on the activities of Virtual Asset Service Providers (VASPs; in Brazil, VASPs are designated as Sociedades Prestadoras de Serviços de Ativos Virtuais, or SPSAVs). The regulatory efforts are led by the Central Bank of Brazil (Banco Central do Brasil, BCB), in collaboration with other regulatory bodies like the Securities and Exchange Commission (CVM) and the Federal Revenue Service (RFB). This framework is built upon the legal foundation established by Law No. 14.478/2022 and Decree No. 11.563/2023.

Brazil formally implemented the Travel Rule with the publication of BCB Resolution 520 in November 2025.

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Key Regulatory Milestones

• ‍Law No. 14.478/2022 and Decree No. 11.563/2023: These legislative instruments set the groundwork for regulating VASPs, mandating that these providers must obtain authorization from the Central Bank to operate in Brazil. The decree specifies the roles and coordination between various regulatory bodies.‍
• Phased Regulatory Approach: The regulatory process is divided into phases, with the first phase aimed at collecting inputs from the public to draft preliminary regulatory texts. These drafts will address operational and authorization aspects of VASPs.‍
• Public Consultation Process: 
  • The first round of consultation, which concluded on January 31, 2024, focused on gathering broad contributions on governance aspects like anti-money laundering (AML) measures, risk management, and blockchain custody monitoring.
  • This consultation specifically included a question about the implementation of the Travel Rule. Question 30 of consultation asked the following: “How can these institutions [virtual asset service providers] ensure compliance with the Travel Rule, as per Recommendation 16 of the Financial Action Task Force?”. Notabene’s response is available here.
  • Following the initial round of consultation, the Central Bank released four additional consultations in 2024 (97, 109, 110, 111, and 122) presenting draft rules that would form the basis of Brazil’s VASP regulatory framework. These consultations informed the final rules adopted in BCB Resolutions 519, 520 and 521, published in November 2025.
    • Consultation 109 proposed the general regulation of virtual asset services, including incorporation, operation, and fee structures.
    • Consultation 110 addressed authorization processes, including transitional treatment for entities already operating in Brazil.
    • Consultation 111 integrated VASP activities into Brazil’s foreign exchange and international capital markets framework.
• On November 10, 2025, the BCB published three key resolutions — 519, 520, and 521 — establishing a comprehensive regulatory framework for VASPs:
  • Resolution 519/2025 defines the authorization process for VASPs. It clarifies how entities must apply for approval by the BCB before engaging in virtual-asset services.
  • Resolution 520/2025 governs how VASPs and other authorised institutions can operate within Brazil’s virtual-asset market. It covers the types of services, governance, risk management, AML/CTF obligations (including Travel Rule requirements), and transition provisions.
  • Resolution 521/2025 – This resolution integrates virtual-asset activities into Brazil’s foreign-exchange regime. It recognises operations such as cross-border payments, stablecoin transactions and transfers involving self-hosted wallets as falling under the FX regulatory framework in Brazil.

Who is the regulatory authority in Brazil?

The Central Bank of Brazil is the regulatory authority.

Is the Crypto Travel Rule mandated in Brazil?

Yes. Brazil formally mandated the Crypto Travel Rule through BCB Resolution 520, published in November 2025.

When is the Crypto Travel Rule enforcement date in Brazil?

Under Article 89 of Resolution 520, the Travel Rule will be implemented in two stages over a period of two years, from 2026 to 2028.

• Phase I runs from February 2, 2026 to February 2, 2027.

During this first phase, the Travel Rule applies only to domestic transactions — so transfers between institutions operating inside Brazil.

• Phase II runs from February 2, 2027 to February 2, 2028.

In this phase, the scope expands to include cross-border transactions, which involve foreign institutions.

Across both phases, SPSAVs are allowed to rely on self-declarations from clients to identify the transacting parties and the purpose of the transaction. The key condition is that these self-declarations must be properly documented and made available to the Central Bank if requested.

Full compliance becomes mandatory on February 2, 2028.

Does Brazil permit a grace period to comply with the Crypto Travel Rule?

Brazil establishes a grace period from February 2, 2026, to February 2, 2028, during which the Travel Rule is implemented in phases as explained in the previous question. 

What is the minimum threshold for the Crypto Travel Rule in Brazil?

Travel Rule information is required for every transaction, regardless of amount.

What personally identifiable information must VASPs collect and share for the Crypto Travel Rule in Brazil?

Under BCB Resolution 520/2025, the originator’s institution must transmit required identifying information for both the originator and the beneficiary for every virtual-asset transfer.

The resolution also requires institutions to report suspicious activity and to notify the Central Bank of Brazil of any difficulties in meeting Travel Rule obligations, including issues arising from the practices of BCB-authorized counterparties.

Are there differences in customer PII requirements for cross-border transfers versus transfers within Brazil?

No. 

What are the non-custodial or self-hosted wallet requirements in Brazil?

BCB Resolution 521/2025 defines self-hosted wallets (“carteiras autocustodiadas”) as wallets where the user controls the private keys without a third-party intermediary.

Under the resolution, transfers to or from a self-hosted wallet are subject to Brazil’s foreign exchange (FX) framework, and VASPs are required to identify the wallet owner.

Why choose Notabene for Crypto Travel Rule Compliance in Brazil?

VASPs and financial institutions, both in Brazil and abroad, can use Notabene’s end-to-end Travel Rule solution to comply with BCB regulations. The platform securely collects and verifies originator and beneficiary information, supports self-hosted wallet identification, and enables pre-transaction due diligence for traceable, compliant transfers.