Central Bank of Brazil Regulates Cryptocurrency Firms
The Central Bank of Brazil has officially implemented operational regulations for cryptocurrency companies operating within the country. Resolution BCB nº 520, published on Monday, outlines the requirements for the establishment and operation of virtual asset service providers (VASPs) and how other financial institutions can offer cryptocurrency intermediation and custody services. According to Marcelo Godke, partner at Godke Advogados and specialist in Corporate and Banking Law, this is the most significant step since the Legal Framework for Cryptoassets (Law 14.478/2022).
Market Organization and Clarity
According to the lawyer, the regulation creates three distinct categories for cryptocurrency service providers: intermediaries, custodians, and brokers (who can intermediate and custody simultaneously). “Intermediaries and custodians cannot combine other modalities; only brokers can do both. This organizes the market and clarifies roles,” he explains.
Governance and Operational Requirements
VASPs must have at least three directors/administrators responsible for key areas such as business operations, AML/CFT, internal controls, risk management, and cybersecurity. “Opening operations as a single-shareholder company is not allowed. It’s minimal governance, but with teeth,” the specialist warns.
Practical Implications of the New Regulations
VASPs and financial institutions must classify specific situations (international payments with crypto, self-custody, stablecoins, etc.) as foreign exchange transactions, apply limits when the counterparty is not authorized, and report monthly.
KYC/KYT procedures, contracts, and operational flows will need adjustments. “Companies and individuals using crypto to pay/receive from abroad will face more scrutiny and, in many cases, need to engage in foreign exchange transactions like traditional remittances,” the lawyer states.
Stablecoins Under Scrutiny
Stablecoins are now subject to clearer regulations. “They fall under the exchange rate regime with currency reference, facilitating supervision and balance of payments statistics,” says Godke.
Resolution 520 clarifies who can provide cryptocurrency services and under what conditions. “By closing loopholes and aligning the sector with the modern exchange framework, the Central Bank increases confidence, comparability, and data—essential for a larger and safer market. Professional operators will benefit; those relying on ‘shortcuts’ will need to adapt,” he explains.
Changes in Customer Relationships
Regarding customer relationships, the rule mandates complete separation between company funds and customer funds (in individualized accounts) and between company crypto and customer crypto (in separate wallets). “There is a mandatory reserve proof policy and a biennial independent audit published on the website. To facilitate liquidity, the company can maintain up to 5% of its own crypto in customer wallets—clearly identified and free of encumbrances. It’s the normative antidote to the old confusion of pockets,” adds Godke.
The regulation also prohibits VASPs from offering credit to customers, raising funds from the public (outside of stock issuance), and participating in the capital of other financial institutions.
Resolution BCB nº 521, dated November 10, 2025, completes the link between virtual assets and the foreign exchange market. By amending Resolutions 277, 278, and 279 (the new exchange framework), the Central Bank defines which cryptocurrency services have an exchange nature and when they fall under the regime of Brazilian capital abroad and foreign capital in the country. “When the operation is, in substance, foreign exchange, it must go through the authorized financial system, with rules, limits, and monthly reporting,” the specialist concludes.
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