Brazil’s cryptocurrency sector is entering a new era with the Central Bank of Brazil’s latest regulations for virtual asset service providers (VASPs). This regulatory framework establishes clear guidelines for these providers, marking a significant step forward for the industry.
The new rules emphasize legal certainty, align with international standards, and impose stricter requirements for governance, compliance, and anti-money laundering efforts. These measures aim to bolster confidence and foster maturity within the market.
With these changes impacting everyone from fintechs and financial institutions to tech companies, investors, and service providers, there’s a growing need for technical and strategic guidance on how to comply with the new regulations.
To discuss the key aspects of the new regulations and their impact on the financial innovation ecosystem, Barcellos Tucunduva Advogados (BTLAW) and CLA Brasil hosted a meeting on December 12th. The event featured Pedro Henrique Nascimento Silva, an auditor and coordinator from the Central Bank.
Silva announced that the Central Bank intends to publish the necessary Normative Instructions by February, before Resolution BCB No. 520/25 takes effect. These instructions will detail important aspects of the regulation, including those related to the foreign exchange market with virtual assets. However, he noted that these topics are still under internal discussion and being adjusted by the regulator.
Thiago Amaral, a partner at Barcellos Tucunduva Advogados (BTLaw) specializing in Payment Methods, Fintechs, and Cryptoassets, provided further insights.
The discussions highlighted the need for VASPs and companies partnering with international exchanges to adapt to the new rules.
One area of concern was the lack of clear regulatory definitions regarding partnerships between companies seeking to work with authorized VASPs. It remains unclear whether these arrangements should be structured under Joint Resolution No. 16/2025, which governs Banking as a Service (BaaS), or under Resolution BCB No. 520/25, which deals with the contracting of relevant services.
In this context, the importance of evaluating the contractual design and allocation of responsibilities between the VASP and the partner company on a case-by-case basis was emphasized.
The new regulations require VASPs already serving Brazilian clients as intermediaries and/or custodians of assets to undergo a formal authorization process with the Central Bank. They must meet requirements related to corporate structure, minimum capital, statutory board, risk management, internal controls, information security, and AML/CFT policies.
Payment institutions, fintechs, and banks offering crypto-related products will need to review their partner networks to ensure they are working with authorized entities or those in the process of authorization. Failure to do so could result in the termination or reconfiguration of certain operations.
This shift is expected to put pressure on younger companies that have thrived in a less regulated environment. However, it also creates opportunities for more robust partnerships with local VASPs, the use of specialized custodians, and the development of products with greater legal certainty and regulatory predictability.
The event also dedicated significant attention to stablecoins, which account for a substantial portion of global trading volume and are gaining traction in Brazil for remittances, international payments, and currency hedging strategies.
Discussions covered international advancements in stablecoin regulation and the ongoing legislative debate in Brazil, including Bill No. 4.308/2024, which addresses the possibility of stablecoin issuance and its impact on the payments and foreign exchange markets.
Participants emphasized that this is a highly dynamic segment that requires constant monitoring by regulators, with systematic data collection on volumes, entity profiles, and clients. This will allow the regulatory framework to be adjusted gradually, preserving innovation while safeguarding the integrity of the system and protecting users.
Another key point was the role of dialogue forums, such as the one organized by BTLAW and CLA Brasil. By bringing together regulators, financial institutions, fintechs, VASPs, industry associations like ABToken, and other experts, these events help align expectations, clarify doubts, and build regulatory and contractual solutions that are more aligned with market realities.
Participants agreed that this continuous interaction is essential for Brazil to advance, safely and competitively, in consolidating a more mature, transparent, and integrated digital asset ecosystem within the traditional financial system.
