Our partner Roberto Panucci was featured in a Valor Econômico article on the Central Bank's new rules for Banking as a Service, set out in Joint Resolutions No. 15, 16 and 17, published today.
Our partner Roberto Panucci was featured in a Valor Econômico article on the Central Bank's new rules for Banking as a Service, set out in Joint Resolutions No. 15, 16 and 17, published today.
Among the changes introduced by these rules, we also highlight:
Full accountability of the BaaS provider: the Central Bank removes any doubt about who is regulatorily responsible for the operation, including when operational steps are outsourced.
Account ownership and traceability: every account used in BaaS must be held in the client's name at the provider institution, strengthening flow control and eliminating room for pooled accounts.
Structural prohibitions for BaaS takers: platforms may not perform functions typical of a banking correspondent, customer service or commercial representative of the authorized institution.
KYC, fraud prevention and AML/CFT as non-delegable functions: execution may be shared; regulatory responsibility always remains with the authorized institution.
Governance elevated to senior management level: BaaS policies and structures must be approved by the executive board or board of directors, with direct accountability of managers.
Standardized naming and communication: JR 17/2025 prohibits brands and terms that could mislead consumers about the authorized nature of the institution.
Closing the side doors in Open Finance: adjustments in JR 15/2025 prevent the system from being used as an indirect onboarding or pseudo-origination channel by unregulated platforms.
