Fernanda Rangel
Roberto Panucci Filho
Tiago Severo Gomes
Diogo Octavio Nebias
Guilherme Teles
Marcelo De CallisBCB Resolution 521, published on November 10, 2025, expands the concept of a foreign exchange transaction to cover international payments and transfers, transactions denominated in foreign currency and the custody of virtual assets of non-residents, including stablecoins. The Central Bank thus begins to supervise flows that until now operated in a "gray area," requiring structured registration, data trails and identification of counterparties.
- Treatment as foreign exchange. BCB Resolution 521 expanded the concept of a foreign exchange transaction to cover certain uses of virtual assets, including stablecoins, when used in international payments, investments or custody for non-residents. This change is eminently regulatory, not tax-related: the Central Bank now supervises such flows within the Foreign Exchange System, requiring registration and reporting, but it does not, by itself, create a new taxable event for IOF purposes. The rule governs "who may" and "how" to operate, without altering the core tax rule of the levy.
- Limits and counterparties. The rule prohibits cash transactions and imposes value limits (where the foreign counterparty is not authorized to carry out foreign exchange transactions). This restriction closes arbitrage loopholes and requires companies to map the licenses of their international counterparties, reviewing governance and compliance to adapt onboarding and partnerships.
- Reporting requirements. Resolution 521 requires that virtual asset transactions classified as foreign exchange be reported to the BCB with granular data: client, counterparty, asset, quantity, denomination and nature of the transaction. This data pipeline creates a regulatory and statistical trail, allowing the Central Bank to monitor the market and close arbitrage opportunities between jurisdictions. It is the first stage in the integration of crypto with the official foreign exchange and capital system.
- Self-custody and traceability. Self-custodied wallets also come within the regulatory radar. When linked to international payments or transfers, they must be identified and attributed to their holder. The BCB intends to require KYT (know-your-transaction) processes and audit trails capable of proving the origin and destination of virtual assets in cross-border transactions.
