Brazil Sets $10K Self-Custody Crypto Reporting Rule

Brazil will require regulated financial and crypto service providers to report transfers of at least $10,000 involving self-custody wallets to the country’s financial intelligence unit from Oct. 1.

The rule applies when virtual assets move to or from wallets where users control their own private keys. Institutions handling qualifying transactions must report them to the Council for Financial Activities Control, or Coaf, rather than requiring wallet owners to file the report themselves.

Transfers Of $10,000 Or More Trigger Coaf Reporting

Resolution BCB No. 588 adds transfers of virtual assets to or from self-custody wallets worth at least the equivalent of $10,000 to Brazil’s list of transactions requiring specific communication to Coaf.

The requirement applies in both directions. A covered institution sending crypto to a customer-controlled wallet or receiving assets from one must report the transaction once it reaches the threshold, even when there are no other indicators of suspicious activity.

The new provision forms part of Brazil’s anti-money laundering and counter-terrorist financing framework and expands monitoring of crypto transfers that move outside institution-controlled wallets.

Rule Does Not Require Users to Surrender Private Keys

The measure does not ban self-custody, impose a $10,000 transaction ceiling or require users to transfer control of their wallets to an exchange or bank.

It also differs from Brazil’s DeCripto tax-reporting framework. Resolution BCB No. 588 creates a specific AML communication to Coaf by covered institutions when qualifying self-custody transfers occur.

The same resolution adds foreign-exchange transactions involving the delivery or receipt of at least $10,000 in physical foreign currency to the mandatory reporting categories.

Separate 24-Hour Transfer Hold Starts January 1, 2027 

Brazil has a separate crypto-transfer rule taking effect Jan. 1, 2027 under Resolution BCB No. 584. Covered institutions must apply a precautionary hold to outbound transfers destined for foreign crypto businesses or self-custody wallets when an individual transaction exceeds $10,000 or a customer’s combined transactions on the same day cross that threshold. 

The rule also allows holds below $10,000 when an institution’s risk controls identify a need for additional review. The maximum standard review period is 24 hours after the relevant funds are received into the wallet, although an institution can release the transfer earlier following a documented risk assessment.

The Oct. 1 reporting requirement comes first. From that date, qualifying transfers to or from self-custody wallets must be communicated to Coaf while users remain free to control their own wallet keys.