A foreign exchange with users in Brazil receives a notice from its local payment partner in November 2026: the account that settles its Pix deposits will be closed, because the exchange is not authorized by the Central Bank. Its users still want to deposit and withdraw reais. What does a VASP need to get a bank account in Brazil, or another way to hold BRL rails?
Since November 6, 2026, financial and payment institutions in Brazil may no longer carry out or enable virtual asset operations with providers that are not authorized by the Central Bank, so authorization status is now the first thing a bank checks. Beyond that, expect a full KYB review, AML policies and proof of the source of funds, and a choice between a bank account, a payment account at a payment institution or an authorized institution that holds the BRL rails.
Why is banking access harder for VASPs in Brazil?
Banks and payment institutions apply their own risk assessment to every client, and virtual asset providers bring specific AML and fraud risks into that review.
Since 2026, that review also has to follow the framework built on Law No. 14,478, of December 21, 2022. BCB Resolutions No. 519, 520 and 521, of November 10, 2025, took effect on February 2, 2026 and now define who may provide virtual asset services in Brazil, and how. A VASP is called a PSAV under Brazilian rules. For what the license itself requires, see what foreign exchanges need to know about Brazil’s VASP license.
What changed on November 6, 2026?
BCB Resolution No. 589, of September 23, 2026, rewrote article 91 of Resolution 520. From November 6, 2026, financial institutions, payment institutions and other institutions authorized by the Central Bank may not carry out or enable virtual asset market operations with providers that are not authorized to operate in Brazil.
The earlier wording also accepted providers “in the process of authorization,” and that phrase is gone. The ban explicitly reaches the opening and maintenance of payment accounts and payment transactions used to enable those operations. For a VASP, the account question and the authorization question are now the same question. The dates behind this rule are explained in what Brazil’s October 30 VASP deadline means.
What types of account can a VASP use?
A VASP that needs to move reais in Brazil has three structures to consider.
1. Bank account at a commercial bank
The VASP holds an account in its own name at a bank in Brazil. It is the most traditional option, and the one where the bank’s own risk appetite weighs most.
2. Payment account at a payment institution
Payment institutions, governed by Law No. 12,865, of October 9, 2013, offer payment accounts used to receive, hold and send funds, including through Pix. For a European reader, the closest analogy is an account at an electronic money institution, though the two regimes are not legally the same.
3. An authorized institution that holds the BRL rails
The VASP does not open its own account. The regulated activity and the BRL accounts sit with an institution authorized in Brazil, and the VASP serves its users on top of that infrastructure under a contract.
Criterion | Bank account | Payment account | Authorized institution |
|---|---|---|---|
Account holder | The VASP | The VASP | The authorized institution |
Depends on the VASP’s own authorization | Yes, from November 6 | Yes, from November 6 | On the institution’s authorization |
Main review | Bank KYB and risk appetite | Payment institution KYB | Contract and partner due diligence |
Control of the client relationship | Full | Full | Defined in contract |
What will the bank or payment institution ask for?
Each institution sets its own onboarding list, and none of these items is an official Central Bank checklist. In practice, a VASP should expect most of the following:
Authorization by the Central Bank of Brazil, now the starting point
Corporate documents, the group structure and the ultimate beneficial owners
AML and KYC policies, and procedures for sharing originator and beneficiary information
Source of funds and a projection of monthly volumes in reais
How client funds are segregated from the company’s own funds
How do the options compare in a real flow? An example
Take a foreign exchange that receives BRL 2 million a month in Pix deposits from Brazilian users. The values are illustrative.
With its own account, the deposits land in an account in the exchange’s name. From November 6, the bank or payment institution has to confirm that the exchange is authorized before serving those flows.
With an authorized institution, users deposit into accounts held by that institution, which credits the exchange’s platform. The institution carries the regulated activity and the KYC obligations defined in the contract.
In both cases, the BRL 2 million needs reconciliation per user, so the exchange can credit each deposit and process each withdrawal.
Need BRL accounts and Pix for your platform in Brazil? See how our banking infrastructure works.
How does Transfero support crypto platforms that need BRL rails?
Transfero’s Banking as a Service (BaaS) lets companies move money in Brazil without becoming a bank, and crypto platforms and wallets are among the businesses it serves.
Digital accounts in BRL, with funds collected and sent through Pix
BRL on-ramps and off-ramps through Pix in the crypto infrastructure, with KYC and AML built in
A published case in which a top-5 global exchange runs BRL ramps, BRZ and KYC in one integration
Transfero Instituição de Pagamento Ltda. is authorized by the Central Bank of Brazil to operate as a payment institution. For digital asset services in Brazil, the group also operates Transfero SPSAV, which has submitted its application for authorization to the Central Bank of Brazil and operates under the applicable transitional framework. Onboarding and contractual requirements depend on the services and operating model.
Questions to ask before choosing where to hold BRL
Is your company authorized by the Central Bank of Brazil, or has it filed?
Do you need accounts in your own name, or can an authorized institution hold the BRL rails?
How much do you move in reais each month, and how many users deposit and withdraw?
Are your AML, KYC and information-sharing procedures documented for a Brazilian review?
How are client funds segregated, and how will deposits be reconciled per user?
Who owns the client relationship and the KYC data in each structure?
Talk to Transfero’s team about BRL rails for your platform in Brazil: get in touch.
Frequently asked questions
Can a foreign VASP open a bank account in Brazil without a local entity?
To operate as a VASP in Brazil, a company must be incorporated in the country, with headquarters and management there, under Resolution 520. Since November 6, institutions may not enable virtual asset operations for providers that are not authorized, so a foreign entity without authorization should expect its BRL flows to go through an authorized institution.
What happens to VASPs that applied for authorization but are not yet authorized?
Under article 88 of Resolution 520, a provider that filed by October 30, 2026 may keep providing its services until the process ends. Article 91 now refers only to authorized providers, while the earlier text also accepted those in the process of authorization.
Is a payment account the same as a bank account?
No. A payment account is held at a payment institution and is used to receive, hold and send funds, including through Pix. A bank account is held at a bank, which can offer a wider range of financial services. Both are subject to the counterparty rule in article 91.
Do Brazilian banks have to serve VASPs?
Article 91 defines which providers institutions may not serve in virtual asset operations. Within that limit, each bank or payment institution decides on onboarding through its own risk assessment and KYC policies.
