Brazil Puts Crypto Wallets Under the Microscope

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  • Brazil’s Central Bank clarifies that there is no ban or transaction cap

  • The new framework adds a second layer of oversight for wallets that are not held by an exchange, as part of efforts to combat fraud

As of October 1, 2026, crypto-asset transfers worth US$10,000 or more, to or from self-custody wallets, must be reported to Brazil’s Council for Financial Activities Control (Coaf). The requirement stems from BCB Resolution No. 588, published on September 23, which amended Circular 3,978/2020.

The regulator stressed that the threshold is solely for reporting purposes and does not represent a ban or a limitation on crypto transactions. Nor does it mean that the transaction is suspicious: reporting does not imply that an operation is illegal, but rather expands the information available for monitoring. The example cited by the Central Bank is a transfer between a virtual asset service provider (VASP) and a wallet directly controlled by the customer.

The measure is based on a technical rationale. According to the BCB, wallets in which users control their private keys provide less information for monitoring and risk assessment than assets held in the custody of regulated entities. The regulation also standardizes the automatic reporting to Coaf of cash exchange transactions of US$10,000 or more.

A second layer of oversight

The resolution does not come alone. In August, the BCB published Resolution 584, which establishes a cautious hold of up to 24 hours on transfers to VASPs incorporated abroad or to self-custody wallets when the amount exceeds US$10,000, either in a single transaction or based on the customer’s total daily amount. That rule takes effect on January 1, 2027.

For lawyer Paulo Portuguez, consulted by BitNotícias, the two regulations are not contradictory, but they do overlap. The hold is intended to prevent fraud before a transfer is executed; the Coaf reporting requirement is based on an objective threshold that does not depend on whether the transaction is deemed suspicious. His interpretation: there is no legal presumption of illicit activity, but there is a regulatory presumption of higher risk associated with self-custody. Self-custody remains permitted, although it now comes with customer identification, verification of the source and destination of funds, precautionary holds and reporting to Coaf.

There is also a difference in scope: the hold takes into account the customer’s total daily transaction volume, while the text of Resolution 588 does not expressly establish the same daily aggregation mechanism.

The context: the region’s largest crypto market

The regulation comes as Brazil, according to Chainalysis’ adoption index, moved more than US$252.5 billion in digital assets in the 12 months through June, accounting for 43.7% of Latin America’s activity. Argentina recorded US$88.5 billion and Mexico US$77.6 billion. The same report says that stablecoin usage in Brazil grew 495%.

Meanwhile, the licensing regime is moving forward: October 1 is the deadline for VASPs already operating in the country to formally submit their applications for authorization to the Central Bank.

The compliance burden falls on exchanges and platforms, which will have to adjust their systems to generate the automatic reports. For users of private wallets, self-custody remains legal, but higher-volume transactions will now be systematically visible to regulators.

 

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