Newsletter (#009/2025) on Fintechs, Banks, Financial Services, and Virtual Assets by Campos Thomaz Advogados

Newsletter (#009/2025) on Fintechs, Banks, Financial Services, and Virtual Assets by Campos Thomaz Advogados

Alerts, materials, and updates on Fintechs, Banks, Financial Services, and Virtual Assets.

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Topics for 2025 – Stay tuned for upcoming newsletters

• Open Finance
• Virtual Assets
• Bank as a Service
• Tokenization
• Artifical intelligence

Alerts

Brazil’s Federal Revenue aligns fintechs with banks in anti–money laundering rules

The Federal Revenue Service has aligned fintechs with financial institutions regarding the obligation to provide information aimed at curbing crimes such as money laundering. The normative instruction, published in the Official Gazette on August 29, 2025, was announced after three major operations against organized crime that uncovered a scheme that allegedly moved about BRL 140 billion illegally, with more than 400 court orders executed in at least eight states. The rule requires payment institutions and participants in payment arrangements to follow the same ancillary obligations of the National Financial System and the Brazilian Payments System related to the e-Financeira, a report that consolidates high-value transactions, and it mandates reporting indications of criminal activity to the authorities. Learn more.

Central Bank improves Pix’s Special Refund Mechanism

On August 28, 2025, the Central Bank of Brazil announced amendments to the Pix Regulation to enhance the Special Refund Mechanism (MED), which enables the return of funds to victims of fraud, scams, or coercion. The measure was updated on September 12, 2025. Currently, refunds are limited to the account initially used in the fraud, a limitation since fraudsters often quickly transfer funds to other accounts, leaving little or no balance available for recovery. Learn more.

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Regulatory Update

BCB Normative Instructions

Enhancement of the Special Return Mechanism (MED) of Pix

Normative Instruction BCB No. 653, 8/28/2025 – Amends Normative Instruction BCB No. 32, of October 26, 2020, which establishes the format, periodicity, and information to be provided by Pix participants, to introduce new obligations resulting from the enhancement of the Special Return Mechanism of Pix.

Publication of Version 7.0 of the Pix Timing Manual

Normative Instruction BCB No. 654, 8/28/2025 – Publishes Version 7.0 of the Pix Timing Manual, which forms part of the Pix Regulation.

Publication of Version 8.0 of the Operational Manual of the Directory of Transactional Account Identifiers (DICT) of Pix

Normative Instruction BCB No. 655, 8/28/2025 – Publishes Version 8.0 of the Operational Manual of the Directory of Transactional Account Identifiers (DICT), which forms part of the Pix Regulation.

Amendments to Document 2062 (Statement of Individual Operational Limits – DLI)

Normative Instruction BCB No. 656, 9/1/2025 – Amends the filling instructions and layout of document code 2062 – Statement of Individual Operational Limits – DLI, as provided for in Normative Instruction BCB No. 85, of March 10, 2021.

Amendments to Criteria for Applying CMN Resolution No. 4,966/2021 and BCB Resolution No. 352/2023

Normative Instruction BCB No. 657, 9/1/2025 – Amends Normative Instruction BCB No. 560, of December 6, 2024, which clarifies the criteria to be observed in the application of CMN Resolution No. 4,966, of November 25, 2021, and BCB Resolution No. 352, of November 23, 2023.

Initiation Standards Manual

Normative Instruction BCB No. 658, 9/5/2025 – Publishes Version 2.9.0 of the Pix Initiation Standards Manual, which forms part of the Pix Regulation.

Amendments to Document 3040 (Credit Risk Data) of the Credit Information System – SCR

Normative Instruction BCB No. 659, 9/8/2025 – Amends the layout and filling instructions of document code 3040 – Credit Risk Data, of the Credit Information System – SCR, governed by Circular No. 3,870, of December 19, 2017, and Circular Letter No. 3,869, of March 19, 2018.

Amendments to MCR Document 6 (Statement of Rural Credit Requirements and Applications)

Normative Instruction BCB No. 660, 9/10/2025 – Amends Document 6 (Statement of Rural Credit Requirements and Applications) of the Rural Credit Manual (MCR).

Operational Procedures of the Restriction Communication System in the National Financial System (BC Protege +)

Normative Instruction BCB No. 661, 9/11/2025 – Establishes the operational procedures necessary for the operation of the restriction communication system for contracting in the National Financial System (SRC), as provided for in BCB Resolution No. 475, of May 26, 2025, called BC Protege +.

Deadlines for Adaptation of IT Service Providers (PSTI) – Information Security and Fraud Management Policy

Normative Instruction BCB No. 664, 9/11/2025 – Establishes deadlines for IT Service Providers (PSTI), in operation on the effective date of BCB Resolution No. 498, of September 5, 2025, to implement the necessary adaptations for compliance with the rules on information security policy and fraud management policy established in the aforementioned Resolution.

Amendments to MCR Document 4 (Summary of Judgment and Review of Coverage Requests)

Normative Instruction BCB No. 665, 9/16/2025 – Amends MCR Document 4 (Summary of Judgment and Review of Coverage Requests) of the Rural Credit Manual (MCR).

BCB Resolutions

Enhancements to the Pix Forum, MED, and Procedures for Changing Keys

Resolution BCB No. 493, 8/28/2025 – Amends Resolution BCB No. 1, of August 12, 2020, which established the Pix payment arrangement and approved its regulation, to adjust provisions related to the operation of the Pix Forum, and amends the regulation annexed to Resolution BCB No. 1, of August 12, 2020, to improve the Special Return Mechanism and the procedures for changing information linked to Pix keys.

Adjustments in the Incorporation and Operation of Payment Institutions (BCB Res. No. 80/2021)

Resolution BCB No. 494, 9/5/2025 – Amends BCB Resolution No. 80, of March 25, 2021, which governs the incorporation and operation of payment institutions, establishes the parameters for filing authorization requests for their operation, and provides for the provision of payment services by other institutions authorized to operate by the Central Bank of Brazil.

Adjustments in the Authorization Processes of Payment Institutions (BCB Res. No. 81/2021)

Resolution BCB No. 495, 9/5/2025 – Amends BCB Resolution No. 81, of March 25, 2021, which governs the authorization processes related to the operation of payment institutions and the provision of payment services by other institutions authorized to operate by the Central Bank of Brazil.

Authorization Criteria for Payment Institutions Participating in Pix

Resolution BCB No. 496, 9/5/2025 – Amends BCB Resolution No. 1, of August 12, 2020, which established the Pix payment arrangement and approved its regulation, to adjust provisions related to the authorization criteria for payment institutions not authorized to operate by the Central Bank of Brazil and which are Pix participants.

Amendments to the Regulation of Wire Transfers (TED)

Resolution BCB No. 497, 9/5/2025 – Amends BCB Resolution No. 256, of November 1, 2022, which regulates Wire Transfers (TED).

Accreditation of IT Service Providers (PSTI)

Resolution BCB No. 498, 9/5/2025 – Regulates, within the scope of the National Financial System and the Brazilian Payment System, the requirements, procedures, and conditions for accrediting IT Service Providers (PSTI) and provides other measures.

Regulation of Access to Siscomex Information

Resolution BCB No. 499, 9/10/2025 – Regulates access to information relating to import and export declarations registered in the Integrated Foreign Trade System (Siscomex) and its use within the Central Bank of Brazil.

Performance Evaluation Regulation for Career Specialists During Probationary Period

Resolution BCB No. 500, 9/10/2025 – Publishes the Performance Evaluation Regulation for Career Specialists of the Central Bank of Brazil during the probationary period.

Enhancement of Fraud Prevention Rules in Payment Services

Resolution BCB No. 501, 9/11/2025 – Amends BCB Resolution No. 142, of September 23, 2021, which provides for procedures and controls for fraud prevention in the provision of payment services to be adopted by financial institutions, other institutions authorized to operate by the Central Bank of Brazil, and payment institutions that are part of the Brazilian Payment System (SPB).

New Regulation of the Central Bank’s Graduate Program (PPG)

Resolution BCB No. 502, 9/11/2025 – Approves the new regulation of the Central Bank of Brazil’s Graduate Program (PPG).

Adjustments to Maximum Value Limits for Pix Transactions

Resolution BCB No. 503, 9/18/2025 – Amends BCB Resolution No. 1, of August 12, 2020, which established the Pix payment arrangement and approved its regulation, to adjust provisions related to the maximum transaction value limits in Pix.

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Produced by Alan Campos Thomaz and João Marcelo Oliveira

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