The Brazilian Central Bank published on August 29, 2017, Resolution N. 4,595, which establishes Compliance guidelines for financial institutions and credit unions.

The institutions subject to regulation by the Central Bank shall implement a compliance program no later than December 31 this year. Among other aspects, the Resolution establishes that:

  • )   The institutions shall assign appropriate personnel to perform compliance-related activities, with clear division of responsibilities of the individuals in order to avoid potential conflicts of interest, especially with the business areas;
  • )   Sufficient resources shall be allocated for the performance of compliance-related activities;
  • )   Measures shall be taken to guarantee the independency and adequate authority of the responsible for such activities; and
  • )   After the implementation of the policy, institutions shall keep available to the Central Bank the relevant documentation.

Institutions shall consider their nature, size, complexity, structure, risk profile and business model when implementing the compliance policy in order to ensure the effective management of their risk.

Click here for the full version of the Resolution.

For more information regarding Resolution 4,595 or other Compliance-related matters, please contact Salim Saud or Bernardo Viana.

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