Every year, companies in the industries covered by Federal Law No. 9,613/1998 (“Money Laundering Prevention Law”) must submit the Communication of Non-Occurrence (“CNO”).
The CNO, based on Article 11, item III, of the Money Laundering Prevention Law, is a regulatory obligation imposed on obligated persons by this Law, in the event that there were no suspicious proposals, transactions, or operations during the year 2024.
Industries specifically regulated by the Council for Financial Activities Control (“COAF”), such as the luxury goods and high-value assets, factoring, and the trade of jewelry, gemstones, and precious metals, are obliged to submit the communication directly to the agency through Siscoaf. Other sectors obliged by the Money Laundering Prevention Law, which have their own specific regulators, such as financial institutions and insurers, must submit the CNO according to the deadlines and conditions set by their respective sectoral regulations.
Complying with the obligations to communicate to COAF is one of the pillars of a strong compliance program, and obligated persons must observe COAF guidelines and the applicable law, as non-compliance can result in penalties and reputational damage.
For more information on the regulations and guidelines for anti-money laundering, contact the Saud Advogados team.