BCB Resolution 521: international stablecoin payments become FX, with a US$100,000 limit and beneficiary data
The Central Bank rule that brings virtual assets into the foreign exchange market changes what a provider may do and what the client must disclose when paying a foreign supplier. Here is the text, article by article.
Historical reference: November 19, 2025. Published on this site on November 2, 2026. Dates in the text identify the period covered.
In this article
Key points
- BCB Resolution 521, of November 10, 2025, amends the foreign exchange rules to cover virtual asset services: international payments and transfers, use of cards abroad and transfers to self-custodied wallets.
- When the counterparty abroad is not an institution authorized to operate in foreign exchange, each international transaction by a provider (SPSAV) is capped at US$100,000.
- The provider must collect the purpose of the payment and the data of the payer or recipient abroad (name, country and relationship with the client).
- Most of the rule applies from February 2, 2026; the rules on purpose, beneficiary identification and reporting apply from May 4, 2026.
A Brazilian company that pays a supplier in China with USDT is, in the Central Bank's eyes, carrying out a foreign exchange transaction. That is the practical consequence of BCB Resolution No. 521, published on November 10, 2025. The overview of the month's three resolutions is in Central Bank publishes Resolutions 519, 520 and 521. This text stays with Resolution 521 and the rules that affect international payments.
- Limit per international transaction for an SPSAV when the counterparty is not authorized to operate in foreign exchange (art. 29, IV)
- US$100,000
- Equivalent limit for foreign exchange brokers and securities brokers and dealers acting as providers (art. 29, II)
- US$500,000
- Reference amount per payment for using one of the purpose tables (Annex III)
- US$50,000
What becomes a foreign exchange transaction
The resolution amends BCB Resolution 277, which governs the foreign exchange market, and adds virtual asset services to the matters it covers. It also changes Resolutions 278 and 279, on foreign and Brazilian capital, to reach external credit and investments made with virtual assets. Under the new art. 76-A, the foreign exchange market now includes services involving:
- international payment or transfer with virtual assets;
- transfers tied to the international use of cards and electronic payment instruments;
- transfers to and from a self-custodied wallet, even without an international payment;
- purchase, sale or exchange of virtual assets referenced to fiat currency.
The text does not use the word “stablecoin.” It speaks of virtual assets referenced to fiat currency, a category that includes USDT and USDC. It also prohibits buying or selling virtual assets with payment or receipt in foreign currency, including on a trading book, and bans the use of cash.
The US$100,000 limit and who may operate
The rule in art. 29 defines who may carry out these transactions and with what ceiling. For an international payment or transfer with virtual assets, when the counterparty is not an institution authorized to operate in foreign exchange, the amount is limited to the equivalent of US$100,000. This is the typical case of a supplier who receives in its own wallet, without going through a foreign exchange institution.
| Who provides the service | Counterparty abroad | Limit |
|---|---|---|
| Virtual asset service provider (SPSAV) | Not authorized to operate in foreign exchange | US$100,000 per transaction |
| Foreign exchange broker, securities broker or dealer, finance company or development agency acting as a provider | Not authorized to operate in foreign exchange | US$500,000 per transaction |
| Bank or Caixa acting as a provider | Not authorized to operate in foreign exchange | The rule sets no ceiling |
The ceiling applies to each payment or transfer with a counterparty not authorized to operate in foreign exchange. The rule does not allow splitting a larger payment into parts to stay below it, and splitting transactions is a red flag under anti-money-laundering rules. For larger amounts, the way forward is to agree with the provider on how the transaction will be handled.
Beneficiary, purpose and documentation
From May 4, 2026, the new art. 76-C requires the provider to obtain from the client the purpose of the payment, with the codes from the foreign exchange rule's tables, and information about the payer or recipient abroad and that party's relationship with the client. The data include name, country and the relationship between the parties (for example, supplier). The reference limit of US$50,000 per payment determines the use of Annex III, which has the simpler codes; above that, the detailed table applies.
For the importer, the information looks like what banks and foreign exchange brokers already ask for in a foreign exchange contract: why you are paying, who receives the money and in which country. The rule does not set a list of documents, but the invoice, the order or the contract showing the supplier's legal name and country help answer. The difference is that the obligation now also exists for stablecoin payments, and the provider answers for it to the Central Bank.
Self-custody, third parties and abroad
- A self-custodied wallet is one in which the owner holds the private key. The rule does not ban it, but the provider must identify the owner and document the verification of the origin and destination of the assets (art. 76-A, § 5).
- Moving third parties' funds through this service is prohibited, except for an institution authorized to operate in foreign exchange that acts in the clients' interest (art. 76-A, § 3).
- When a provider abroad sits in the middle of the flow, the Brazilian provider must check whether it is under prudential and conduct supervision, or belongs to a group subject to consolidated supervision (art. 76-B, § 2).
- Providers already operating may continue if they meet the deadlines to apply for authorization, which must include the request to operate in foreign exchange (art. 29, § 5).
Dates that matter
- 11/10/2025BCB Resolution 521 is published.
- 02/02/2026Arts. 76-A and 76-B, the amendment to art. 29 and the other rules take effect, including the classification of the transactions as foreign exchange.
- 05/04/2026Art. 76-C (purpose and beneficiary data), art. 82-A (reporting), the new information annex and the changes on external credit and foreign direct investment take effect.
- 5th of each monthMonthly deadline to send the Central Bank the information on the previous month's transactions (art. 82-A).
- 10/30/2026Deadline ends for those already operating to apply for authorization (Resolution 520).
The report covers international payments and transfers, transfers tied to cards, movements to and from self-custodied wallets and the monthly total of purchases, sales and exchanges of assets referenced to fiat currency.
What remains open
The resolution is a foreign exchange rule and does not deal with taxes. How payments will be taxed, including the IOF charged on foreign exchange transactions (see the status of the rate in IOF: the back and forth in Congress and the Supreme Court), is not detailed in the text. How the information is submitted also depends on a complementary rule: art. 82-A says it will be sent “in the form defined by the Central Bank of Brazil,” which had not been published as of November 19, 2025. Companies should consult their accountant and legal counsel before changing their payment routine.
Frequently asked questions
Is paying a foreign supplier with USDT a foreign exchange transaction?
Yes. Under BCB Resolution 521, an international payment or transfer made with virtual assets is a foreign exchange transaction from February 2, 2026. The collection of the purpose, the beneficiary data abroad and the reporting to the Central Bank apply from May 4, 2026.
What is the US$100,000 limit in Resolution 521?
It is the ceiling per international virtual asset transaction made by a service provider (SPSAV) when the counterparty abroad is not an institution authorized to operate in foreign exchange. For foreign exchange brokers and securities brokers and dealers acting as providers, the limit is US$500,000; for banks, the rule sets no ceiling.
What does the provider need to know about the supplier?
The purpose of the payment and the data of the payer or recipient abroad, such as name, country and relationship with the client. This obligation applies from May 4, 2026.
Was self-custody banned?
No. The resolution allows transfers to and from self-custodied wallets, but requires the provider to identify the owner and document the verification of the origin and destination of the assets.
When does Resolution 521 take effect?
Most of it on February 2, 2026. The rules on purpose, beneficiary identification and reporting take effect on May 4, 2026.
Found it useful? Share it with anyone who pays suppliers abroad.
Sources
- Resolução BCB nº 521, de 10 de novembro de 2025 · Banco Central do Brasil, Nov 10, 2025
- Banco Central regulamenta o uso de ativos virtuais e o funcionamento e a autorização das instituições que atuam nesse mercado · Banco Central do Brasil, Nov 10, 2025
- Resolução BCB nº 277, de 31 de dezembro de 2022 (mercado de câmbio) · Banco Central do Brasil, Dec 31, 2022
- BC publica regras para o mercado de criptoativos e mantém permissão para autocustódia · Capital Aberto, Nov 10, 2025
- Lei nº 14.478, de 21 de dezembro de 2022 · Presidência da República, Dec 21, 2022
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