Central Bank Resolution No. 521/2025 on Virtual Assets in FX

The resolution places several categories of virtual-asset service activity within the foreign-exchange framework when performed by prestadoras de serviços de ativos virtuais, commonly translated as virtual asset service providers or VASPs. The covered activities include international payment or transfer using virtual assets, transfers connected to international use of cards or other electronic payment instruments, transfers to or from self-custodied wallets that do not involve an international payment or transfer, and the purchase, sale or exchange of virtual assets referenced to fiat currency.

The measure does not operate as a standalone licensing statute. Instead, it links the exchange-market treatment of virtual-asset services to Brazil’s broader VASP authorization framework. Societies providing virtual-asset services may perform the covered exchange-market services only where they fit within the Central Bank’s authorization framework and, where applicable, are authorized to operate in the foreign-exchange market. For those institutions, the rule also restricts operations involving physical cash in national or foreign currency.

Resolution 521/2025 includes specific conduct and risk-control provisions. It bars the purchase or sale of virtual assets with payment or receipt in foreign currency, including transactions executed through an order book. It also prohibits the movement of third-party funds through in-scope virtual-asset services, except where the VASP is providing services to an institution authorized to operate in the foreign-exchange market and that institution is acting for its own clients.

For self-custodied wallet transfers within the rule’s scope, the VASP must identify the owner of the wallet and maintain documented processes to verify the origin and destination of the virtual assets. Where a transaction involves a foreign VASP, the Brazilian provider must check whether the foreign entity is subject to effective prudential and conduct supervision or belongs to a group subject to effective consolidated supervision. If the foreign jurisdiction does not provide those requirements, the provider must document its risk assessment before doing business with that entity.

The rule adds an information-reporting layer to Brazil’s exchange-market rules. Institutions authorized to operate in foreign exchange must report information on in-scope virtual-asset service operations to the Central Bank by the fifth day of the month after the operation, and the same reporting obligation applies to specified VASP entities. Annex II-A requires operational data such as transaction date, purpose, client identification, virtual-asset denomination, quantity transferred, value reference in reais and, for international transfers, information about the overseas payer or recipient and the relationship with the client.

Resolution 521/2025 also extends the treatment of virtual assets into international capital-market reporting. It provides that external credit and foreign direct investment operations involving virtual assets must follow Resolution BCB 278, including credit transactions in fiat-referenced virtual assets and capital contributions made in virtual assets. Brazilian capital abroad involving virtual assets must follow Resolution BCB 279.