Banks, Financial Services, Fintechs and Digital Assets Newsletter – March 2025

REGULATIONS

Central Bank of Brazil 

BCB IN No. 595, of March 21, 2025

BCB Normative Instruction (“IN”) No. 595, of March 21, 2025, discloses the procedures, documents and information necessary for submitting requests for authorization and cancellation of the authorization to carry out the bookkeeping activity of book-entry duplicates, referred to in BCB Resolution No. 339, of August 24, 2023.

To apply for authorization to carry out the bookkeeping activity of book-entry duplicates, the following must be submitted:

• • a request according to the applicable template in the Financial System Organization Manual (“Sisorf”);
  • a draft of the regulations governing the electronic system for book-entry duplicates in accordance with BCB Resolution 339;
  • an independent assessment to ensure that the system and its regulations are compatible with the provisions of BCB Resolution 339 and current regulations;
  • proof of compliance with minimum capital and equity requirements, including payment of share capital, audited financial statements and updated balance sheet; and
  • a statement confirming success in ratification tests according to the applicable Sisorf template.

When requesting the cancellation of authorization, the following must be submitted:

• • a request according to the applicable Sisorf template;
  • a reasoned justification highlighting strategic, corporate and economic-financial aspects;
  • proof of notification to participants of the intention to cancel;
  • proof of closure or transfer of outstanding obligations, open transactions and booked duplicates; and
  • a liability statement according to the applicable Sisorf template.

BCB IN No. 595 entered into force on the date of its publication.

Read BCB IN No. 595 in full

BCB IN No. 594, of March 19, 2025

BCB IN No. 594, of March 19, 2025, amends Normative Instruction No. 491, of July 23, 2024, which establishes:

• • the guidelines for registering access devices used to initiate Pix transactions and manage Pix keys; and
  • defines the maximum amount allowed to initiate Pix transactions on an unregistered access device.

The regulation adjusts the rules relating to the registration of access devices. The changes include:

• • the definition of new procedures to identify the account holder;
  • the implementation of additional security measures through mechanisms such as smartcards, cryptographic tokens and biometric access to confirm the identity of the account holder, and their registration.

BCB IN No. 584 will enter into force on July 01, 2025, for the provisions that amend Article 7, sole paragraph, and Article 9, paragraph 2, of BCB IN No. 491. The remaining provisions entered into force on the date of their publication.

Read BCB IN No. 594 in full

BCB IN No. 593, of March 19, 2025

BCB IN No. 593, of March 19, 2025, announces version 7.5 of the Operational Manual for the Transaction Accounts Identifier Directory (“DICT”), which is part of the Pix Regulation, in accordance with article 2 of the Regulation annexed to BCB Resolution No. 1, of August 12, 2020.

The new regulation, which repeals BCB Instruction 561 of December 06, 2024, will enter into force on different dates:

• • on July 01, 2025, for amendments to sections 3.1, 3.2, 7.1 and 7.2; and
  • on October 01, 2025, for amendments to sections 5.1, 5.2, 6.1 and 6.2.

The remaining provisions entered into force on the date of their publication.

Read BCB IN No. 593 in full

Access the DICT Operating Manual

BCB IN No. 592, of March 19, 2025

BCB IN 592, of March 19, 2025, extends entry into force of Normative Instruction No. 590, of February 05, 2025, which amends BCB Normative Instruction No. 330, of November 24, 2022.

BCB IN No. 330 consolidates the procedures for registering information in the Central Bank’s Information System on Entities of Interest (“Unicad”), referred to in BCB Resolution No. 209, of March 22, 2022, and establishes procedures for registering contractors, referred to in Article 5 of Joint Resolution No. 6, of May 23, 2023.

Given the extension, BCB Normative Instruction No. 590 entered into force on March 03, 2025, but will only take effect as of May 02, 2025.

BCB IN No. 592 entered into force on the date of its publication.

Read BCB IN No. 592 in full

BCB IN No. 591, of March 17, 2025

IN BCB No. 591, of March 17, 2025, releases version 2.8.1 of the Manual of Standards for Pix Initiation, which is part of the Pix Regulation, under Article 2 of the Regulation annexed to BCB Resolution No. 1, of August 12, 2020.

The new manual version is available on the website of the Central Bank of Brazil (“BC”), in the page dedicated to the manuals that integrate the Pix Regulation.

In addition, the new regulation repeals BCB IN No. 553 of November 29, 2024.

BCB IN No. 591 entered into force on the date of its publication.

Read BCB IN No. 591 in full

Access the Manual of Standards for Pix Initiation

BCB Resolution No. 457, of March 06, 2025

BCB Resolution No. 457, of March 06, 2025, amends the regulation attached to BCB Resolution No. 1, of August 12, 2020, which establishes the Pix payment scheme and approves its regulation, in order to improve Pix’s security mechanisms.

The regulation requires participating financial and payment institutions to ensure that the names of people linked to Pix keys are consistent with those registered in the Federal Revenue Office’s Individual Taxpayers’ Register (“CPF”) and Corporate Taxpayers’ Register (“CNPJ”) databases. Therefore, Pix participants will be required to exclude keys belonging to people who are not in good standing with the Federal Revenue Office.

The BC will actively monitor compliance with these guidelines and may apply penalties in cases of non-compliance. The BC seeks to prevent scammers from keeping keys registered in disagreement with the Federal Revenue Office’s records.

Finally, the BC has authorized the return of any money in unregistered access devices. The regulation, which restricted Pix transactions on unregistered devices to a maximum amount of BRL 200.00, was implemented in November 2024.

BCB Resolution 457 entered into force on the date of its publication, taking effect:

• • as of April 01, 2025, for provisions amending or repealing Articles 60 (paragraph 2), 66, main section, item V, 67 (sole paragraph) and 71, main section, items I and II of the Pix Regulation;
  • as of July 01, 2025, for provisions amending Articles 57 (main section), 57 (paragraph 4, item II) and 64 (paragraph 1) of the Pix Regulation; and
  • as of October 01, 2025, for provisions amending Articles 68 and 70 of the regulation.

The other provisions entered into force immediately.

Read BCB Resolution No. 457 in full

Read the BC article on the topic

BCB Resolution No. 458, of March 20, 2025

BCB Resolution 458, of March 20, 2025, establishes an interdepartmental working group (“GTI”) to organize the BC’s activities at the 30th United Nations Climate Change Conference (“COP30”).

The COP30 GTI will be responsible for:

• • raising important topics and proposals concerning the Central Bank’s activities at the conference;
  • planning and proposing activities and programs relating to the event;
  • coordinating the participation of financial institutions and other agents;
  • providing financial support for travel and activities;
  • organizing the logistics required for the event; and
  • providing periodic reports on the progress of activities and a final report with conclusions and actions taken.

BCB Resolution No. 458 entered into force on the date of its publication.

Read BCB Resolution No. 458 in full

BCB Resolution No. 459, of March 25, 2025

BCB Resolution No. 459, of March 25, 2025, amends BCB Resolution No. 339, of August 24, 2023, to provide for ratification tests aimed at authorizing bookkeeping, registration and centralized deposit systems of book-entry duplicates, in addition to establishing the implementation schedule for interoperability functionalities.

BCB Resolution No. 459 entered into force on the date of its publication.

Read BCB Resolution No. 459 in full

BCB Resolution No. 460, of March 25, 2025

BCB Resolution 460, of March 25, 2025, terminates the publication of the Banking Economics Report (“REB”) and repeals BCB Resolution 56, of December 16, 2020.

The BC has indicated that the Financial Stability Report will now include part of the information that would be published in the REB. According to the BC, information not published in the Financial Stability Report may still be published in other BC communication vehicles.

BCB Resolution No. 460 entered into force on the date of its publication.

Read BCB Resolution No. 460 in full

Read the BC article on the topic

CMN Resolution No. 5,201, of February 27, 2025

The National Monetary Council (“CMN”) Resolution No. 5,201, of February 27, 2025, proposes to change the annual global limits authorized for contracting credit transactions with government agencies and entities in 2025 and 2026, by amending the Annex to CMN Resolution No. 4,995, of March 24, 2022.

CMN Resolution No. 5,201 entered into force on March 17, 2025.

Read CMN Resolution No. 5,201 in full

NEWS

BC and Fenasbac launch virtual open innovation program

The BC, together with the National Federation of Central Bank Civil Servants’ Associations (“Fenasbac”), launched LIFT Data, a virtual program aimed at encouraging open innovation.

The initiative seeks to stimulate the use of public data in developing technological solutions to challenges faced by the National Financial System. The first edition will focus on sustainability, encouraging international collaboration, and using public information to generate positive environmental and social results. Applications for the program are open until April 13 on the website: liftdata.com.br.

The partnership between the BC and Fenasbac has been ongoing since 2018 and focuses on fostering financial innovation through LIFT (Laboratory of Financial and Technological Innovations), which already operates on three fronts: LIFT Lab; LIFT Learning; and LIFT Challenge. Now, LIFT Data aims to expand its ecosystem, making sustainability a central topic.

Read the BC article in full

SPA-MF launches initiative to report payment methods involved in illegal betting

The Ministry of Finance’s Secretariat for Prizes and Betting (“SPA/MF”) has published SPA/MF Ordinance No. 566/2025, establishing guidelines for intermediating financial transactions in sports betting and online gaming.

The regulation governs Article 21 of Law No. 14,790/2023, imposing restrictions on transactions involving unauthorized operators, in addition to expanding control obligations for financial institutions, payment institutions and payment scheme providers.

Institutions must adopt internal mechanisms to identify suspicious transactions, and if any evidence of irregularities is found, they must be reported to the SPA/MF within 24 hours via the Electronic Information System (“SEI”). To reinforce control, the SPA/MF will maintain a public list of certified operators, including those whose authorization requests have been denied.

If these requirements are not met, the institution can be held liable for facilitating the operation of irregular agents, which can result in penalties ranging from fines to the revocation of operating licenses. Penalties must be applied in accordance with SPA/MF Ordinance No. 1,225/2024 and SPA/MF Ordinance No. 1,233/2024, under the terms of Articles 41 and 42 of Law No. 14,790/2023.

Read our client alert on this topic

Court decision allows service of process by NFT in case involving digital assets

Judge Paulo Furtado de Oliveira Filho, of the 2nd Bankruptcy and Judicial Reorganization Court, allowed the use of NFT to serve a motion to toll the statute of limitations.

The legal measure was filed by a company’s bankruptcy estate, seeking to toll the statute of limitations and hold accountable people who own digital assets acquired with third-party funds. Given the difficulty in identifying the defendants, the judge allowed the service of process to be carried out via NFT.

The judge also pointed out that there is a possibility that transactions with crypto assets could be traced via blockchain. The case records indicate that around 11,200 bitcoins were acquired, currently valued at more than BRL 5 billion.

Access the case records in full

See the decision in full