The Central Bank of Brazil (BCB) regulates Virtual Asset Service Providers under Resolutions 519 and 520. BCB authorization is mandatory for any entity seeking to operate as a VASP in Brazil — one of the world's largest virtual asset markets.
Brazil is one of the highest-volume virtual asset markets globally. The Central Bank of Brazil (BCB) administers the VASP authorization regime under BCB Resolution 519 (authorization framework) and BCB Resolution 520 (modality structure), placing Brazil among the most substantively regulated virtual asset jurisdictions in Latin America.
Authorization is pursued in two phases. A favorable Phase 1 decision allows the applicant to continue operating under the BCB transition regime while the final analysis is completed. Phase 2 consolidates governance, financial crime controls, and the full dossier through to final BCB authorization.
Marensa Advisory delivers the full BCB authorization engagement in partnership with a Brazil-licensed regulatory correspondent — covering business model mapping, modality selection, AML/CFT programme design, corporate structuring, and BCB liaison throughout both phases.
Discuss Brazil VASP AuthorizationBCB Resolution 520 establishes three VASP modalities. The correct modality is confirmed during Phase 1 business model mapping — it determines capital requirements, prudential obligations, and governance structure.
BCB applies particular scrutiny to the following areas. These are built into both phases of the engagement from the outset, not added at the end.
Brazil is a high-volume, high-scrutiny VASP market. BCB authorization is substantive — the process requires genuine corporate, prudential, governance, and AML/CFT readiness, not just a document submission.
We deliver the engagement in partnership with a Brazil-licensed regulatory correspondent, combining our international GRC expertise with direct BCB representation on the ground. The result is an authorized VASP that can actually operate — with banking, compliance, and governance in place from day one.
The minimum engagement term is 12 months — from Phase 1 diagnosis through final authorization and initial post-license compliance.
Start the ConversationModality is confirmed during the Phase 1 business model mapping exercise, once your precise service scope and transaction journey are documented. As a general guide: platforms facilitating transactions without holding principal risk are typically Intermediary (A); platforms safeguarding client assets without executing trades are typically Custodian (B); platforms combining both, or taking principal positions, are typically Broker (C). Broker carries the highest capital and prudential requirements.
Under Joint Resolution BCB/CMN No. 14, minimum share capital ranges from R$10.8M to R$37.2M (approximately USD 2.1M to 7.3M at current rates). Intermediary and Custodian alone sit toward the lower end of that range; Broker — combining both activities — sits toward the higher end. The exact figure is confirmed with our Brazilian correspondent once modality is determined and communicated to BCB.
The full authorization process — from Phase 1 diagnosis through Phase 2 submission to final BCB authorization — is scoped as a minimum 12-month engagement. A favorable Phase 1 decision, which allows continued operation under the BCB transition regime, is achievable within the earlier months of the engagement depending on the quality and completeness of the application.
Yes — a favorable Phase 1 BCB decision allows the applicant to continue operating under the BCB transition regime while the final Phase 2 analysis is being completed. This is one of the most commercially valuable aspects of the two-phase structure: early structuring and a strong Phase 1 submission preserves operational continuity during the authorization process.
BCB-authorized VASPs are subject to Brazil's AML/CFT law and BCB supervision standards. The authorization dossier must include a full AML/CFT policy suite, a designated MLRO, a customer due diligence framework proportionate to VASP risk, transaction monitoring procedures, suspicious transaction reporting processes, Travel Rule compliance, and an AML/CFT risk assessment. BCB reviews AML/CFT submissions carefully — a weak or generic programme is a primary cause of authorization delays or rejection.
Yes. BCB authorization requires a local presence in Brazil — including a local director and registered address. These are provided as part of the engagement through our Brazil-licensed regulatory correspondent, billed at a local services monthly rate for the duration of the engagement and beyond if continued local presence is required.