Compliance
Written by
Nicole Meneghetti
•
Partner and Head of Compliance
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On August 7, 2026, Brazil's Central Bank published Resolução BCB nº 584, extending to virtual asset service providers the fraud prevention rules previously applicable to the payments system (Resolução BCB nº 142/2021). The resolution creates an analysis window before the execution of certain higher-risk transfers, effective January 1, 2027.
For Unblock, this regulatory development confirms a direction that has guided our operation from day one: fraud prevention as a structural component, not a feature added under deadline pressure.
Because building trust requires more than efficient payments. It requires a robust compliance framework capable of keeping pace with regulation in real time.
What the resolution establishes
Resolução 584 introduces art. 2-B into Resolução 142/2021, establishing a precautionary hold of up to 24 hours before executing virtual asset transfers, counted from the moment the funding assets are received into the wallet.
The measure does not apply to every transfer. It applies when all of the following conditions are present simultaneously:
Higher-risk destination: A foreign entity operating in the virtual asset market, or a self-custody wallet, one whose private key is held exclusively by the holder with no intermediary.
Relevant amount: Transactions exceeding $10,000, per transaction or in aggregate on the same day on behalf of the client.
The hold may also be triggered when the institution's own risk management policies indicate it (§ 1º, III). The scope covers virtual asset services defined in art. 5º, items I through V, of Law 14,478/2022, including stablecoins.
Two points are central to reading the resolution correctly:
The measure is exclusively precautionary: It is intended for risk analysis and does not result in permanent unavailability of assets (§ 1º, I and II).
The 24-hour window is a ceiling: Once analysis is complete, the institution may release the hold before that limit through a documented, reasoned decision (§ 5º).
A new trigger on top of existing requirements
Resolução 584 introduces a new triggering condition, that is, a specific situation that now activates the analysis based on the category of destination and amount, rather than solely on atypicality or suspicion. The operational capacity to hold, trace and document transactions, however, was already required of virtual asset service providers.
Resolução BCB nº 520/2025 already mandates, among other obligations:
Establishing limits and temporary blocks on atypical or suspicious transactions (art. 43, § 2º, VI)
Maintaining records available to the Central Bank for at least five years (art. 43, § 2º, VII, and art. 45, II)
Providing originator and beneficiary data in transfers, in line with the Travel Rule (art. 44, sole paragraph)
Monitoring sanctions lists and risk jurisdictions (art. 43, § 2º, V)
For institutions that built these controls effectively, Resolução 584 represents an additional parameterization, not a reconstruction. That is the difference between keeping pace with regulation and reacting to it.
How Unblock is positioned
Unblock operates within the Central Bank's regulatory requirements for virtual assets and foreign exchange and is in the process of obtaining a VASP authorization, with specialized legal counsel.
Our Know Your Transaction (KYT) controls, wallet screening and on-chain monitoring, supported by blockchain intelligence, already structure risk analysis by fund origin, counterparty and jurisdiction. Exactly the axes the new rule reinforces (§ 2º).
Our commitment to partners and clients is direct:
Transparency: Whenever a transfer undergoes analysis, the client is notified with a clear indication of the precautionary nature of the measure and the applicable time frame.
Proportionality: Analysis is calibrated by risk. Transactions consistent with the client's profile and regular usage do not encounter unnecessary friction.
Responsible agility: Analysis is completed in the shortest time consistent with security, treating the 24-hour ceiling as a limit, not a standard.
Intact custody: The measure is precautionary. The assets remain the client's and are not subject to permanent unavailability.
What changes for Unblock users
For now, nothing. The rule takes effect on January 1, 2027 and Unblock is already adapting its systems and processes in advance so that the transition is transparent. As the effective date approaches, we will communicate the operational details directly.
"Fraud prevention is part of the infrastructure we offer, not an add-on. Resolution 584 reinforces a risk-based approach we already apply: assessing exposure, tracing the origin of funds and acting with precision on suspicious activity. For us, this goes beyond regulatory compliance. It is about protecting our partners and preserving the integrity of the operations we intermediate." – Nicole Meneghetti, Partner and Head of Compliance.
This content is informational and does not constitute legal or financial advice. It is based on BCB Resolution 584, issued on August 7, 2026, and BCB Resolution 520, issued on November 10, 2025. For the full text, please visit the Brazilian Central Bank website.
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