What is a PSAV: Brazil's definition of a virtual asset service provider (VASP)
PSAV is the Brazilian term for a virtual asset service provider. See the definition in Law 14,478/2022, the difference between PSAV, SPSAV and VASP, who can be a PSAV and what the Banco Central requires.
PSAV stands for prestadora de serviços de ativos virtuais, Portuguese for virtual asset service provider, or VASP. It is the name Brazilian law gives to companies that buy, sell, exchange, transfer or hold crypto assets on behalf of customers, such as exchanges and custodians. Since 2 February 2026, these companies need authorization from the Banco Central do Brasil to operate in Brazil, with a transition period for those already operating.
This article explains the concept from the text of the law and the Banco Central’s resolutions. The regulations are published in Portuguese; the quotes below are our translation.
What is the legal definition of a PSAV?
The definition is in art. 5 of Law 14,478/2022, Brazil’s legal framework for virtual assets:
A virtual asset service provider is a legal entity that carries out, on behalf of third parties, at least one of the virtual asset services, understood as:
I. exchange between virtual assets and national or foreign currency;
II. exchange between one or more virtual assets;
III. transfer of virtual assets;
IV. custody or administration of virtual assets or of instruments that allow control over virtual assets; or
V. participation in financial services and provision of services related to the offering by an issuer or the sale of virtual assets.
Two elements of the definition decide who is a PSAV. The company must be a legal entity and must provide the service on behalf of third parties. Any one of the five services is enough to fall under the definition.
What counts as a virtual asset?
Art. 3 of the same law defines a virtual asset as “a digital representation of value that can be traded or transferred by electronic means and used to make payments or for investment purposes”. Bitcoin, ether and stablecoins fall under this definition.
The law excludes four categories:
- national and foreign currencies;
- electronic money, under Law 12,865/2013;
- loyalty program points, rewards and similar instruments;
- assets whose issuance or trading is already provided for in law or regulation, such as securities and financial assets.
PSAV, SPSAV and VASP: what is the difference?
The three acronyms show up together and are often confused.
| Acronym | Meaning | Where it appears |
|---|---|---|
| PSAV | Any virtual asset service provider | Law 14,478/2022 and BCB Resolution 520, art. 2, XII |
| SPSAV | Virtual asset service provider company, set up for this purpose and authorized by the Banco Central | BCB Resolution 520, art. 4 |
| VASP | Virtual asset service provider, the English equivalent of PSAV | International standards, such as FATF’s |
Every SPSAV is a PSAV, but not every PSAV is an SPSAV. Under art. 2, XII, of BCB Resolution 520, virtual asset service providers are “virtual asset service provider companies and institutions authorized to operate by the Banco Central do Brasil that act in the virtual asset market”. A bank that starts offering crypto custody becomes a PSAV without becoming an SPSAV.
Who regulates PSAVs in Brazil?
The Banco Central. Law 14,478 says PSAVs “may only operate in the country with prior authorization from a body or entity of the federal public administration” (art. 2), and Decree 11,563/2023 gave that role to the Banco Central.
The Banco Central published its rules on 10 November 2025, in three resolutions that took effect on 2 February 2026:
- BCB Resolution 519, on the authorization process;
- BCB Resolution 520, on the incorporation and operation of providers;
- BCB Resolution 521, which brought part of virtual asset operations into the FX market.
Who can be a PSAV?
There are two paths.
The first is to set up an SPSAV, in one of three types: intermediary, custodian or broker, which does both. An SPSAV must be a limited liability company or a corporation, have at least three officers accountable to the Banco Central and apply for authorization before it starts operating.
The second is to be an institution the Banco Central has already authorized. Art. 20 of Resolution 520 allows commercial, FX, investment and multiple banks, Caixa, CTVMs, DTVMs and FX brokers to provide intermediation and custody of virtual assets. They do not apply for a new authorization: they file a formal notice with the Banco Central, together with the technical certification under BCB NI 701.
An individual cannot be a PSAV, because the law refers to a legal entity. Resolution 520 also bars an SPSAV from having a single individual as its sole partner (art. 14, § 2).
What does a PSAV have to comply with?
The main obligations come from Resolution 520 and the normative instructions that detail it:
- keep customer funds and assets separate from the provider’s own, with proof of reserves and an independent audit (arts. 28 to 30);
- maintain anti-money laundering and cybersecurity policies (arts. 34, 47 and 48);
- inform customers about risks, fees and the absence of FGC coverage (arts. 53, 61 and 68);
- apply the travel rule to transfers, mandatory from 2 February 2028 (arts. 44 and 89);
- in an SPSAV’s authorization application, file the AML/CFT reasonable assurance report required by BCB NI 739;
- on transfers to or from a self-custody wallet, identify the wallet’s owner, as explained in the article on self-custody wallet verification.
What are the deadlines for providers already operating?
A company that was already providing virtual asset services on 2 February 2026 has 270 days to apply for authorization, until 30 October 2026 (Resolution 520, art. 88). Companies that file on time may keep operating until the Banco Central decides. Companies that do not file must stop providing the services within 30 days after the deadline.
From 6 November 2026, banks and other authorized institutions may no longer carry out or enable virtual asset market operations with providers that are not authorized to operate in Brazil (art. 91, as amended by BCB Resolution 589/2026).
Frequently asked questions
Is a crypto exchange a PSAV?
Yes. An exchange that buys, sells or exchanges virtual assets for customers provides the services in items I and II of art. 5 of Law 14,478 on behalf of third parties. If it also holds customers’ assets, it provides the custody service in item IV as well.
Is a company that only invests in crypto with its own money a PSAV?
The law’s definition covers those who provide the services on behalf of third parties. A company that only trades for its own account does not meet that element of the definition. The specific case is worth reviewing, because any service provided to customers, even an ancillary one, may change the answer.
Does a PSAV need Banco Central authorization?
Yes. Art. 2 of Law 14,478 requires prior authorization, and Resolution 520 details how it works. An SPSAV applies for authorization; an already authorized institution files the formal notice.
How Clav helps
Clav is a compliance platform for PSAVs. It has BCB Resolution 520 and the normative instructions mapped as frameworks, with requirements organized into controls and evidence, so the team can track what is missing for authorization and what has to be kept up after it.