Regulatory Compliance Made Simple
Streamline VASP authorization and maintain compliance with Brazilian Central Bank regulations. Clav centralizes your entire compliance framework in one platform.
Everything You Need for Compliance Success
Manage regulatory requirements, track evidence, and maintain compliance posture with our comprehensive platform.
Framework Management
Track multiple compliance frameworks simultaneously with real-time progress monitoring and detailed requirement categorization.
Control Tracking
Manage 419+ compliance controls with automated assignment tracking, status monitoring, and evidence validation.
VASP Authorization (BACEN)
Comply with the Central Bank of Brazil's Phase 1 and Phase 2 authorization process through structured evidence management and approval workflow automation.
Policy Management
Access pre-configured compliance policies with version control, template library, and lifecycle management.
Evidence & Documentation
Upload and manage compliance evidence with automated status tracking and complete audit trail.
Compliance Testing
Integrate automated tests and manual verifications with real-time pass/fail tracking and overdue monitoring.
Clav's content and legal frameworks produced by Paiva Gomes Advogados
Compliance and Authorization Timeline
Complete and detailed flow of regulatory obligations from the Central Bank of Brazil for virtual asset service providers.
02/02/2026ENTRY INTO FORCE
Ground zero for the effectiveness of BCB Resolutions 519 and 520/2025
Complete Details & Obligations
- VASP must be 'in operation' on this date
- Beginning of the 270-day compliance period countdown
- Final deadline: 10/29/2026
02/02/26 until BCB DecisionCOMPLIANCE PERIOD
270 days to request and be in compliance + compliance period extends until BCB's decision on PHASE 1
Complete Details & Obligations
- Duration: 270 days to file and be in compliance
- Compliance period extends until BCB's decision on Phase 1
- Observe Art. 88 (Res. 520)
- PROHIBITED to assume new modality
PROTECTED PERIOD
During this period it is PROHIBITED to assume new service modalities. Use this time to structure all necessary policies, processes, and documentary evidence.
Until 10/29/2026FILING MOMENT
Deadline to file authorization request with BCB
Complete Details & Obligations
- Authorization Request:
- • File request with BCB
- • Indicate modality: Intermediary, Custodian or Broker
- • Note: Missing this deadline requires ceasing operations within 30 days
- Compliance Evidence (Proof of Compliance):
- 1. Risk Management Structure:
- • Market Risk
- • Credit Risk
- • Operational Risk
- • Liquidity Risk
- 2. Cybersecurity Policy:
- • Documented policy
- • Incident Response Plan
- 3. Internal Controls and AML/CFT:
- • Anti-Money Laundering Prevention
- • Compliance with Law 13.810
- 4. Accounting Regulation:
- • Compliance with Cosif
- • Audit Structure
- DATA Information (details in next event)
CRITICAL DEADLINE
Failure to meet this deadline implies mandatory cessation of activities within 30 days. This is the final deadline to file with BCB.
From Filing until End of Phase 1REPORTING - RECURRING DATA SUBMISSION
Data reporting obligations to BCB throughout Phase 1 (regulation pending publication on how reporting will be done)
Complete Details & Obligations
- [DAILY] Balances and Custody:
- • Customer accounting balances
- • Own custody position
- • Third-party custody position
- [MONTHLY] Proofs and Staking:
- • Proof of Reserves (PoR)
- • Staking Assets Report
- [GENERAL] Registration and Complementary Data:
- • Submission of information to CCS (National Financial System Customer Registry)
- • Other requested complementary information
REPORTING REQUIREMENTS
Maintain accurate and timely reporting throughout the entire Phase 1 process to ensure compliance.
After FilingAUTHORIZATION PROCESS START (BCB)
Central Bank begins formal review of application
Complete Details & Obligations
- Analysis divided into two phases
- Phase 1: Checklist and Reputation
- Phase 2: Capacity and Business
Post-FilingPHASE 1
Initial analysis focused on basic compliance and suitability
Complete Details & Obligations
- BCB analyzes the following criteria:
- 1. Proof of Activity:
- • Proof of being active on 02/02/2026
- • Operational evidence from the milestone date
- 2. Unblemished Reputation of Controllers/Administrators:
- • Criminal background analysis
- • Verification of legal proceedings
- • History in the National Financial System (SFN)
- • Inquiries and administrative proceedings
- 3. Minimum Capital and Equity:
- • Share capital verification
- • Proof of adequate net worth
- 4. Directors (minimum of 3):
- 4.1 Types of directors responsible for:
- a) conducting the activities and business developed by the institution;
- b) preventing and combating money laundering and the financing of terrorism and the proliferation of weapons of mass destruction;
- c) the institution's internal control systems and compliance with current regulations;
- d) the risk management structure, capital management, and information disclosure policy of the institution;
- e) asset segregation
- f) relevant services
- h) responsible for contracting the entity established abroad for custody
- ❗ The designation of the same director for the aforementioned responsibilities is permitted, except in cases of incompatibility, conflict of interest, or cases not permitted by legal and regulatory norms.
ANALYSIS IN PROGRESS
BCB is conducting detailed review. Ensure all documentation is complete and accessible for regulatory review.
BCB DecisionEND OF COMPLIANCE PERIOD
CRITICAL MILESTONE - From here on: FULL Compliance
Complete Details & Obligations
- From the BCB's decision on Phase 1:
- • The 'grace period' ends
- • FULL Compliance (Law 14.478 and Res. 519/520/521)
- • Even without final Phase 2 license, all obligations must be met
CRITICAL REGULATORY MILESTONE
After Phase 1 decision, the compliance period ends. From this point on, the entity must operate in FULL compliance with Law 14.478 and Resolutions 519/520/521.
Post-Phase 1PHASE 2
In-depth analysis of viability, structure and governance
Complete Details & Obligations
- BCB conducts in-depth analysis on 5 pillars:
- 1. Economic-Financial Capacity and Origin of Resources:
- • Financial capacity of controllers
- • Lawful origin of resources (UBO Due Diligence)
- • Traceability of investment chain
- • Equity analysis of partners
- 2. Viability of Enterprise and Corporate Governance:
- • Sustainable business plan
- • Realistic financial projections
- • Adequate governance structure
- 3. IT Infrastructure Compatible with Risks:
- • Robust technology systems
- • Information security
- • Contingency and continuity plan
- 4. Business Knowledge by Management:
- • Proven experience in the sector
- • Technical training in virtual assets
- • Regulatory and operational knowledge
- 5. Physical Address and Infrastructure:
- • Own physical address (coworking/shared prohibited)
ANALYSIS IN PROGRESS
BCB is conducting detailed review. Ensure all documentation is complete and accessible for regulatory review.
FinalBCB ANALYSIS ON AUTHORIZATION
Central Bank's final decision
Complete Details & Obligations
- Publication in the Official Gazette
- Authorization for full operation
- Start of regular operations under continuous supervision
How Clav Works
Setup Your Frameworks
Select and configure the compliance frameworks relevant to your VASP operations.
Assign Controls
Distribute compliance controls to team members and track assignments in real-time.
Upload Evidence
Submit documents, test results, and other evidence to demonstrate compliance.
Monitor Progress
Track completion rates, review statuses, and maintain audit-ready compliance posture.
Why Choose Clav?
Accelerate Authorization
Reduce the complexity of VASP regulatory compliance with structured workflows and automated progress tracking.
Never Miss a Requirement
Clav automatically stays aligned with the most recent Brazilian regulatory updates, ensuring your compliance framework evolves as new requirements are released.
Team Collaboration
Enable seamless collaboration across compliance officers, risk managers, and documentation teams.
Audit-Ready Reports
Generate comprehensive compliance reports with complete audit trails and evidence documentation.
Ready to Simplify Your Compliance Journey?
Join leading VASPs who trust Clav for their regulatory compliance management. Be among the first to experience the future of compliance.