Our Proposal
Confidential Proposal · Ref: FIL-BRA-2026-01
Brazil VASP Licensing
BCB Authorization: Phase 1, Phase 2, and Ongoing Compliance
A licensing proposal for Virtual Asset Service Provider (VASP) authorization before the Central Bank of Brazil (BCB), delivered by Fintech & Innovation Ltd in partnership with a Brazil‑licensed regulatory correspondent.
Prepared by
Fintech & Innovation Ltd (FIL)
fintechinnovation.io
Prepared for
Brazil VASP authorization engagement
Executive Summary
This proposal, prepared by Fintech & Innovation Ltd (FIL), sets out the process and cost of securing Virtual Asset Service Provider (VASP) authorization in Brazil before the Central Bank of Brazil (BCB), delivered in partnership with a Brazil‑licensed regulatory correspondent.
The engagement runs across two regulatory phases under BCB Resolutions 519 and 520, a defined fee and payment plan, and a set of capital and commitment parameters, each explained below.
BCB is the regulator
Authorization is pursued directly before the Central Bank of Brazil for any entity seeking to operate as a VASP.
Transition regime
A favorable Phase 1 decision allows continued operation under the transition regime while BCB completes its final analysis.
Compliance advantage
Early structuring aligns corporate, prudential, operational and governance decisions before deeper BCB review begins.
Regulatory Path and Modality Selection
BCB Resolution 519 frames the Phase 1 and Phase 2 analysis structure. BCB Resolution 520 supports the choice of modality below — toggle to compare.
Modality A · Virtual Asset Intermediary
Assessment of whether the client’s service scope, transaction journey and operating model fit this modality.
Modality B · Virtual Asset Custodian
Assessment of whether the client’s activities center on safekeeping and control of client virtual assets rather than executing trades.
Modality C · Virtual Asset Broker
Assessment of whether broker treatment aligns more closely with the intended activities and regulatory exposure.
FIL Recommendation on Modality Selection
- Modality is confirmed during the Phase 1 business model mapping exercise, once the client’s precise service scope and transaction journey are documented.
- Entities that do not take principal risk or hold client assets are typically better suited to intermediary treatment.
- Entities whose core function is safeguarding client assets, without executing trades, should plan for custodian treatment and its strict segregation and liability regime.
- Entities combining both intermediation and custody in one legal structure should plan for broker‑level prudential requirements, including the higher end of the minimum capital range, from the outset.
Engagement Phases
Click a phase to see its scope.
Fees and Payment Plan
Professional fees for the Brazil VASP authorization engagement. Explore the schedule, the local services rate, and the full first‑year cost.
Total professional fee across all 12 installments: USD 83,000. Hover or tap a bar for the exact amount.
| Engagement Cost Summary | Total (USD) |
|---|---|
| Professional fee (Phase 1 and Phase 2, 12 installments) | USD 83,000 |
| Local services (12 months at USD 3,500/month) | USD 42,000 |
| Full first‑year engagement total | USD 125,000 |
Local services monthly fee
- Local director
- Local registered address
Billed monthly for the duration of the engagement. Continues on the same monthly basis beyond the minimum 12‑month term if the entity requires ongoing local presence.
Capital and Engagement Requirements
Two parameters apply to the engagement and are inputs to the fee structure above.
Minimum Share Capital
USD 2.1M – 7.3M
Range under Joint Resolution BCB/CMN No. 14 (R$10.8M–R$37.2M), based on the activities communicated to BCB. Intermediary or Custodian alone sits toward the lower end; Broker, combining both, sits toward the higher end. To be confirmed with our Brazilian regulatory correspondent once modality is set.
Minimum Engagement Term
12 months
The authorization process, from Phase 1 diagnosis through final BCB authorization and initial post‑license compliance, is scoped as a minimum one‑year engagement.
Key Compliance Workstreams
High‑sensitivity topics addressed across both phases.
Custody
Virtual asset custody and custody reports
Private keys
Protection, control and management
Segregation
Client versus proprietary asset controls
Cybersecurity
Information security and incident response
AML/CFT
Financial crime controls and monitoring
Risk management
Policies, lines of defense, controls
Third parties
Relevant providers and cloud services
Continuity
Business continuity and operational resilience
Next Steps
To proceed, we require the following. Check items off as they’re received.
- Confirmation to proceed with Phase 1 diagnosis and the preferred VASP modality (intermediary, custodian, or broker)
- Confirmation of the funding plan for the applicable minimum share capital (USD 2.1M–7.3M, depending on modality)
- Corporate structure chart, and management and shareholder information
- Business model documentation: service scope, client profiles, transaction journey, technology architecture
- Local director and registered address arrangements
- Signed engagement letter and initial payment
Terms and Conditions
- This proposal is valid for 30 days from the date of issue.
- All amounts are quoted in USD.
- The first installment is payable upon signature, prior to commencement of work.
- Local services fees are payable monthly in advance for the duration of the engagement.
- Services outside the defined scope may be requested and billed separately.
- Necessary expenses are excluded from the fees and are reimbursable by the client. FIL may request advances or direct payment for expenses above USD 250.
- BCB authorization is subject to regulatory approval and is not guaranteed by FIL.
- This proposal is confidential and prepared solely for the named recipient above.