SPSAV, BACEN and you: what Brazilian regulation actually guarantees

When a company asks us "are you regulated?", the correct answer is not yes or no. It's: "we are in the process of authorization as an SPSAV with the Central Bank of Brazil, under Joint Resolution 13/2024." And that makes all the difference — it's not marketing, it's a concrete operational and legal distinction.

Understanding what this process means in practice is what separates a well-founded partnership decision from a shot in the dark.

"Regulation is not a seal. It's a set of obligations the platform assumes before the State — and that you can hold them to."

What is an SPSAV

SPSAV stands for Sociedade Prestadora de Serviços de Ativos Virtuais (Digital Asset Service Provider). It's the legal designation created by Law 14,478/2022 — the legal framework for digital assets in Brazil — for companies that act as intermediaries for digital assets in the country.

To operate as an authorized SPSAV, the company must go through an authorization process with the Central Bank of Brazil, which evaluates, among other aspects:

Corporate structure and integrity of controllers and executives
Technical and operational capacity of the platform
Anti-money laundering and terrorism financing prevention policies (AML/CFT)
Segregation of own assets and client assets
Governance mechanisms, internal controls and risk management
Capacity to process complaints and maintain an ombudsman channel

Regulatory context

Joint Resolution 13/2024 of the Central Bank and CVM establishes detailed rules for authorization and operation of SPSAVs in Brazil. Companies already operating before the regulation have a deadline to adapt and apply for authorization.

Brazilian financial regulation — The Central Bank of Brazil is the body responsible for the authorization and supervision of SPSAVs in the country.

What changes for you when operating with an SPSAV in the authorization process

Authorization is not instantaneous. Companies that started the process before the regulatory deadline can operate legally during the review — provided they have filed the application and are complying with applicable obligations.

What this guarantees for you in practice:

Active AML/CFT obligations The company is required to maintain an anti-money laundering and terrorism financing prevention program. This includes KYC, KYB, transaction monitoring and reporting to COAF when applicable.

Asset segregation required Your assets cannot be mixed with the platform's. This protects you in case of operational or financial problems with the intermediary.

Mandatory ombudsman channel The company is required to maintain a complaint service channel with a regulated response deadline. You have a formal path to contest operations.

Executive accountability Partners and executives of the company are personally liable for irregularities. This creates an incentive to operate within the rules.

What regulation does not guarantee

Being regulated does not make an OTC infallible. Regulation establishes a minimum floor of quality and accountability — not a ceiling. Operational problems, out-of-market spreads and poor service can exist even in regulated platforms.

Regulation guarantees you have legal instruments to demand accountability. It doesn't guarantee you won't need to use them.

Practical conclusion

Operating with an SPSAV in the BACEN authorization process is the safest form available today in the Brazilian market. But diligence in choosing the platform remains your responsibility.

How to verify the regulatory status of an OTC

Ask directly whether the company has an authorization process filed with the Central Bank
Request documentation of the protocol or process number at BACEN
Verify the company has an active CNPJ and corporate purpose compatible with digital asset intermediation
Check whether there is a published AML/CFT policy and an operational ombudsman channel
Observe whether the company signs formal contracts for each operation — it's a requirement of a regulated operation

A platform that operates exclusively informally, without a CNPJ, without a contract and without a published compliance policy is not in the authorization process — regardless of what it claims.

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Rica Morais Chief Operating Officer · SuitCoin

Economist from Unicamp, Rica has been COO of SuitCoin since its founding — including the SPSAV licensing process with the Central Bank. Lecturer at FIA and startup mentor. Writes about what actually matters for those making financial decisions using crypto.