BCB Resolution 521: crypto, foreign exchange and the new reporting regime
BCB 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 custody of…
BCB 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 custody of virtual assets for non-residents, including stablecoins. The Central Bank thus begins to supervise flows that until then ran in a "gray zone", requiring structured registration, a data trail and identification of counterparties.
1.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 essentially regulatory, not tax-related: the Central Bank begins to supervise such flows within the Foreign Exchange System, requiring registration and reporting, but it does not by itself create a new taxable event for IOF. The rule governs "who may" and "how" to operate, without changing the tax's basic rule of incidence. 𝐌𝐨𝐫𝐞 𝐨𝐧 𝐈𝐎𝐅 𝐢𝐧 𝐭𝐡𝐞 𝐜𝐨𝐦𝐦𝐞𝐧𝐭𝐬.
2.Limits and counterparties The rule prohibits cash transactions and imposes value limits (when the counterparty abroad is not authorized to conduct foreign-exchange operations). 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.
3.Reporting Resolution 521 requires virtual asset transactions classified as foreign exchange to be reported to the BCB with granular data: client, counterparty, asset, quantity, denomination and nature of the transaction. This data pipe creates a regulatory and statistical trail, allowing the Central Bank to monitor the market and close arbitrage between jurisdictions. It is the first stage of the integration between crypto and the official foreign-exchange and capital system.
4.Self-custody and traceability Self-custodied wallets also come onto 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.
