On November 3, 2025, the Central Bank of Brazil (“BCB”) and the National Monetary Council (“CMN”) published new regulations that expand the situations in which deposit accounts and payment accounts may be compulsorily closed. These include:
- BCB Resolution No. 518 (“BCB Res. 518”), which amends BCB Resolution No. 96 of May 19, 2021, concerning the opening, maintenance, and closing of payment accounts; and
- CMN Resolution No. 5,261 (“CMN Res. 5,261”), which amends Resolution No. 4,753 of September 26, 2019, concerning the opening, maintenance, and closing of deposit accounts.
The changes introduced by the BCB and the CMN also aim to eliminate so-called “contas-bolsão”, which are characterized by account holders using funds in their accounts to carry out transactions on behalf of third parties, such as payments, receipts, or settlements, with the intent of concealing or replacing those third parties’ financial obligations. The aim was to improve the control and prevention mechanisms of financial institutions and those authorized by the BCB, promoting greater integrity and security within the National Financial System.
The regulations will come into effect on December 1, 2025.
As of the effective date of BCB Res. 518 and CMN Res. 5,261, financial institutions and entities authorized to operate by the BCB must close payment and/or deposit accounts of clients, as applicable, in which the following are identified:
- irregularities in the information provided by the account holder, considered to be of a serious nature; or
- the provision of services by the account holder that constitute financial or payment services within the scope of the National Financial System or the Brazilian Payment System, without proper legal authorization or in non- compliance with current CMN or BCB regulations.
It is noted that the situation described in item (ii) above includes, but is not limited to, the use by the account holder of funds held in payment accounts or deposit accounts, as the case may be, for payments, receipts, or compensation of obligations on behalf of third parties, the “contas-bolsão”, which may allow the concealment or substitution of financial obligations of such third parties and make their identification unfeasible.
Financial institutions and entities authorized to operate by the BCB that offer deposit and/or payment accounts to their clients, as applicable, must:
- use their own criteria to identify “contas-bolsão”, including information from public or private databases;
- document and submit for approval by the institution’s board of directors the criteria used to identify “contas-bolsão”; and
- keep available to the BCB, for a minimum of ten (10) years, the documentation of the criteria used to identify “contas-bolsão,” as well as documentation related to the closure of deposit and/or payment accounts closed for these reason.
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