On November 10, 2025, the Central Bank of Brazil (“BCB”) published Resolutions BCB Nos. 519, 520, and 521, which inaugurate the regulatory regime for virtual assets in the country. The package defines who can provide services with virtual assets, how the authorization process for operation will work, and in which situations crypto transactions will be treated as foreign exchange and international capital transactions. The regulations result from Public Consultations Nos. 97/2023, 109/2024, 110/2024, and 111/2024, which included contributions from participants in the private sector, financial institutions, technology companies, associations, law firms, investors, and foreign agents.
With BCB Resolution No. 519, SPSAVs – Virtual Asset Service Providers – were created. These entities now operate within a prudential perimeter equivalent to that applied to the National Financial System, incorporating requirements for governance, prevention of money laundering and terrorist financing (AML/CFT), cybersecurity, customer protection, internal controls, and reporting to the regulator.
Resolution BCB No. 520 defines the authorization process for SPSAV (Small and Medium-Sized Virtual Asset Management Companies), establishes general and specific rules applicable to the segment, and provides for a transition regime for institutions already operating with virtual assets, which will need to adapt to the BCB's requirements to continue operating in compliance.
The most structural point of the change is in BCB Resolution No. 521: payments, transfers, purchase, sale or exchange of virtual assets referenced in fiat currency will now be treated as foreign exchange transactions.
In practice, this brings stablecoins — tokens that mirror the value of fiat currencies, such as the dollar or euro — into the official exchange rate perimeter. Thus, transactions with stablecoins begin to follow the rules of the foreign exchange market.
The regulation also imposes a limit of US$100,000.00 per transaction when the counterparty is not an institution authorized to operate in foreign exchange. Conversely, there has been a relaxation of self-custody: it is permitted, provided that the provider identifies the portfolio owner and maintains documented processes to track the origin and destination of the assets.
The regulation also stipulates that service providers implement formal asset segregation mechanisms, ensuring the separation between the providers' own assets and the assets of clients/users. These elements must be included in a specific policy, accompanied by methods for verifying reserves and biennial independent audits, reinforcing layers of reliability and asset protection similar to those required in the custody of traditional financial assets.
The three resolutions will come into effect on February 2, 2026; and, starting May 4, 2026, it will become mandatory to provide information to the Central Bank on foreign exchange transactions and international capital transactions carried out with virtual assets.