On August 28, 2026, Brazil’s Financial Activities Control Council (“Coaf”) imposed a BRL 7.4 million fine on Stellantis Automóveis Brasil, reaching both the company and its administrators, for failing to comply with rules to combat and prevent money laundering (“AML”). The penalty is part of a broader enforcement push: several luxury brands and automakers have also been fined this year.
Business and individuals dealing in luxury and high-end goods – such as vehicles and luxury fashion – qualify as “obligated parties” under Coaf’s regime. For this reason, they must report unusual transactions, keep clients’ records up to date, and maintain a formal AML policy, regardless of whether the transaction itself shows any sign of wrongdoing.
Specific reporting thresholds are described in Coaf’s Resolution 25/2015, which requires mandatory reporting of cash payments of BRL 30 thousand or more, whether in a single transaction or across multiple transactions within a 6 months period. Although dealing with cash is not illegal, it must be reported to Coaf.
Recent enforcement actions have targeted failures in reporting, client’s recordkeeping and AML policy, i.e., the absence of adequate controls. This reflects a two-pronged approach by Coaf, combining prevention and remediation: obligated parties are expected not only to have functioning AML controls, but also to correct gaps once they are identified.
It is also worth noting that reports made to Coaf are confidential and may not be disclosed to clients, which makes internal readiness, rather than after-the-fact explanations, the only real safeguard. Therefore, obligated parties should treat this as an opportunity to review their AML controls. For more information, contact Saud Advogados.