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On April 30, 2026, the Central Bank of Brazil (“BCB”) enacted Resolution No. 561 (“BCB Resolution 561”), which amends BCB Resolution No. 277, dated December 31, 2022 (which regulates the foreign exchange market and the inflow and outflow of funds in Brazilian reais and foreign currency) with the purpose to update and improve the regulatory framework applicable to international payment or transfer services (“eFX”). BCB Resolution 561 will take effect on October 1, 2026, and arises directly from the Public Consultation No. 124/2025 (“CP 124”), made available by the BCB to gather input on potential improvements to the provisions governing eFX.
The eFX service is the mechanism that enables the following international transactions: (i) the purchase of goods and services, either in person or through a digital payment solution integrated into an e-commerce platform; (ii) unilateral transfers limited to US$10,000.00; (iii) transfers between accounts held by the same account holder, between Brazil and abroad, also subject to a US$10,000.00 limit; (iv) cash withdrawals in Brazil or abroad; and, as introduced by BCB Resolution 561, (v) transfers of funds related to investments in the financial and capital markets, in Brazil or abroad, subject to a limit of US$10,000.00 per transaction.
Set out below are the key changes introduced by BCB Resolution 561:
Expansion of the Scope of eFX Activities
As anticipated, once BCB Resolution 561 takes effect, eFX services will also be permitted for transfers related to investments in the financial and capital markets, in Brazil or abroad, up to a limit of US$10,000.00, or the equivalent amount in other currencies, per transaction.
Restriction of the List of eFX Providers
BCB Resolution 561 will restrict the list of institutions authorized to act as eFX providers. Under the new rule, eFX services may be provided exclusively by institutions authorized to operate by the BCB, including: (i) banks; (ii) Caixa Econômica Federal; (iii) development agencies; (iv) credit, financing and investment companies; (v) securities brokerage firms; (vi) securities distribution companies; (vii) foreign exchange brokerage firms; and (viii) payment institutions authorized to operate by the BCB that provide services as electronic money issuers, post-paid payment instrument issuers or acquirers, regardless of whether they are authorized to operate in the foreign exchange market.
By way of background, under the prior rule, eFX services could also be provided by payment institutions non-authorized by BCB and payment initiators service providers, exclusively for the purchase of goods and services and cash withdrawals, subject to the previously applicable limitations. In addition, other legal entities not regulated by the BCB were permitted to provide eFX services exclusively to enable the purchase of goods and services through a digital payment solution offered by the eFX provider and integrated into an e-commerce platform, limited to US$10,000.00 per transaction.
The new rule provides that authorized institutions interested in providing eFX services may only begin such activities 5 business days after registering the relevant service type in the Information System on Entities of Interest to the Central Bank (Sistema de Informações sobre Entidades de Interesse do Banco Central – “Unicad”).
Entities that currently provide eFX services but are not included in the list of eligible institutions may continue operating only if they apply for authorization to operate as a payment institution by May 31, 2027. If authorization is denied or not requested, such entities must cease providing eFX services within 30 days after: (i) the expiration of the above deadline, if no authorization request has been submitted; or (ii) notification of the denial or dismissal of the authorization request.
Operational Requirements
BCB Resolution 561 introduces the definitions of “remitting user” (usuário remetente), meaning the individual or legal entity that is the initial ordering party of the international payment or transfer; “recipient user” (usuário destinatário), meaning the individual or legal entity identified by the remitting user as the final recipient of the international payment or transfer; and “foreign counterparty” (contraparte no exterior), meaning the nonresident individual or legal entity that is the immediate source or destination of the funds.
The resolution also provides that the eFX provider must have a contractual relationship with the foreign counterparty and must adopt the know-your-customer procedures set forth in BCB Circular No. 3,978, dated January 23, 2020, which addresses anti-money laundering and counter-terrorist financing requirements (“BCB Circular No. 3,978”).
Prohibition on the Use of Virtual Assets in Certain eFX Transactions
A significant addition introduced by BCB Resolution 561, which was not expressly detailed in the draft released under CP 124, is the prohibition on the use of virtual assets for payments or receipts between the eFX provider and its foreign counterparty. In addition, for legal entities that are subject to the transition period in this segment, such payments or receipts may only be carried out through a foreign exchange transaction or through a third-party interest movement in a nonresident account denominated in Brazilian reais and maintained in Brazil. The use of virtual assets is prohibited.
Treatment of Gift Cards and Low-Value Payment Instruments
Finally, the rule provides for the possibility of delivering Brazilian reais, through a payment instrument limited to BRL 1,000.00, by the remitting user to the eFX provider, with no possibility of reloading or cash withdrawal. In such cases, the eFX provider must establish a contractual relationship with the issuer and adopt the know-your-customer procedures set forth in BCB Circular No. 3,978.
BaaS and eFX
Although CP 124 sought input on the possibility of providing eFX services through a Banking as a Service (“BaaS”) model, BCB Resolution 561 does not expressly regulate the BaaS model for eFX currently.
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