The Council for Financial Activities Control (“Coaf“), the Financial Intelligence Unit (UIFs”) in Brazil and responsible for anti-money laundering, combating the financing of terrorist financing, and the proliferation of weapons of mass destruction (“AML/CFT“), published the new integrated management report (“Report“), which presents the results achieved by the body in 2024.
The Report offers a concise overview of the activities developed by Coaf, highlighting the main results achieved in AML/CFT related themes. The highlights of the 2024 Report include (i) the measures to enhance the financial intelligence quality, along with promoting its proper use by competent authorities;(ii) intensifying the risk-based approach in the system for preventing money laundering and terrorist financing; (iii) consolidating the National Risk Assessment (Avaliação Nacional de Riscos – “ANR”) as the main tool for enhancing the Brazilian PLD/FTP system;
(i) The measures to enhance the financial intelligence quality, along with promoting its proper use by competent authorities:
In 2024, 18,762 Financial Intelligence Reports (“RIFs”) were prepared based on 7.5 million operation communications received from obligated parties, as well as notifications from competent authorities throughout the year – which was higher than the 16,411 RIFs issued in 2023.
Additionally, Coaf carried out 25,271 information exchanges with domestic authorities, such as the Public Prosecutor’s Office, the Federal Revenue, the Office of the Comptroller General (CGU), as well as 412 exchanges were recorded with of other UIFs from different countries, reinforcing international cooperation.
Regarding the strategic objective of enhancing the understanding of the PLD/FTP system and Coaf’s roles among society and institutional actors, the agency held 29 meetings with competent authorities in 2024, alongside with other seminars and meetings on the topic. These events aimed to demonstrate how the information generated by Coaf is applied in the financial intelligence production process, promoting greater understanding and collaboration.
In 2023, 14 meetings were held, reflecting a significant increase in Coaf’s engagement with authorities and institutional actors in 2024.
(ii) Intensification of the Risk-Based Approach in the AML/CFT system
In 2024, according to the analysis of financial intelligence, Coaf estimated that over 500,000 obligated persons should have registered at Coaf given the activities performed. Based on these numbers, Coaf intensified the Risk Based Approach in order to prioritize enforcement actions towards the obligated persons that pose greater risk for the AML/CFT system.
Through this strategy, Coaf conducted Electronic Compliance Assessment (Avaliação Eletrônica de Conformidade – “Avec”) towards 527 obligated persons, which led 268 Preliminary Investigations. Out of the 268 Investigations, 23 led to Administrative Sanctioning Proceedings (PAS).
The penalties applied throughout 2024 add up to BRL 38.6 million, a relevant increase compared to the R$7.7 million recorded in 2023, which demonstrates Coaf’s intensifying its enforcement.
(iii) Consolidating the National Risk Assessment as the main tool for improving the Brazilian AML/CFT system
In Brazil, in order to establish the National Risk Assessment as the cornerstone for enhancing the AML/CFT system and to align with FATF international standards, the ANR Working Group (“GTANR”), Coaf undertook a comprehensive review and update of the ANR methodology for Terrorist Financing.
The ANR allows Coaf to collect information, identify, assess, and understand the risks in the AML/CFT system in Brazil, and based on these risks, implement appropriate and proportional strategies to mitigate them. This process involves collaboration between government authorities, the private sector, and civil society, and is essential for Brazil’s evaluation by the FATF.
For 2025, an update to the methodology of the National Money Laundering Risk Assessment is planned. After the completion of these updates, a new cycle of the ANR will begin, with a specific focus on countering the terrorism financing, strengthening the Brazilian AML/CFT system and ensuring greater efficiency in addressing strategic risks.
Trends for 2025:
In 2025, several initiatives and strategic changes are shaping the work of the agency, such as strengthening institutional integration, both domestically and internationally, investing in the use of artificial intelligence for tracking illicit financial activities, and expanding its educational initiatives beyond its regulatory role
These trends highlight Coaf’s continued commitment to keeping up with technological and regulatory advancements, strengthening the Brazilian financial system.
The intensification of Coaf’s regulatory agenda in recent years has created an ongoing challenge for obligated entities to monitor and update their internal policies and regulations in order to ensure compliance with Coaf’s regulations. For more information, please contact Saud Advogados.