Documentation Index
Fetch the complete documentation index at: https://support.wepayments.com.br/llms.txt
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Cross-border operations are subject to strict regulatory requirements in Brazil, including anti-money laundering (AML) and counter-terrorist financing (CFT) regulations. This guide outlines the key compliance requirements for international merchants operating with WEpayments.
Regulatory framework
WEpayments operates in compliance with Brazilian regulations, including:
| Regulation | Scope |
|---|
| Law nº 9.613/1998 | Money laundering crimes and prevention |
| Law nº 13.260/2016 | Terrorist financing |
| Law nº 13.810/2019 | UN Security Council sanctions compliance |
| BCB Circular nº 3.978/2020 | PLD/FTP procedures for financial institutions |
| BCB Resolution nº 277/2022 | eFX transactions |
| COAF Resolution nº 29/2017 | Reporting obligations |
💡 WEpayments maintains a comprehensive PLD/FTP Policy (Prevention of Money Laundering and Terrorist Financing) aligned with these regulations.
Key compliance concepts
| Concept | Definition |
|---|
| Money Laundering | Process of concealing illegal origin of funds to make them appear legitimate (placement → concealment → integration) |
| Terrorist Financing | Providing funds for terrorist purposes – funds may be legitimate or illicit |
| Beneficial Owner | Natural person who ultimately owns, controls, or significantly influences a legal entity |
| PEP (Politically Exposed Person) | Individual in a prominent public position, plus their family and close associates (status applies for 5 years after leaving office) |
| COAF | Financial Intelligence Unit of Brazil – receives and analyzes suspicious transaction reports |
Prevention methods: KYC, KYB, KYP, KYE, KYS
WEpayments employs multiple “Know Your” processes to mitigate compliance risks:
| Process | Applies to | Purpose |
|---|
| KYC (Know Your Customer) | Merchants/clients | Collect information, profile monitoring, detect suspicious patterns |
| KYB (Know Your Business) | Legal entities | Verify corporate structure, beneficial owners |
| KYP (Know Your Partner) | Business partners | Screen before contracting, monitor relationships |
| KYE (Know Your Employee) | Employees | Hiring criteria, conduct monitoring, training |
| KYS (Know Your Supplier) | Suppliers/vendors | Pre-contract screening, payment monitoring |
Required documentation for cross-border payments
Per transaction
| Document | Description |
|---|
| Nota Fiscal | Brazilian tax invoice from the receiving company |
| Invoice | Commercial invoice from the paying foreign company |
Onboarding / first transaction
| Document | Description | Reusable |
|---|
| Commercial contract | Agreement between parties | Yes |
| KYC/KYB documents | Company registration, tax ID, beneficial owner info | Yes |
CBD-specific documentation (if applicable)
| Document | Source |
|---|
| Medical prescription | Patient |
| ANVISA authorization | Patient |
| Identity document | Patient |
Compliance monitoring and analysis
What is monitored
| Dimension | Analysis |
|---|
| Transaction velocity | Frequency of payments to/from same beneficiary |
| Amount patterns | Values relative to historical behavior |
| Beneficiary relationships | Connections between payers and payees |
| Restrictive lists | Sanctions, PEP, watchlists, negative media |
Monitoring outcomes
| Outcome | Description |
|---|
| Auto-approved | No risk indicators – transaction proceeds normally |
| Flagged for review | Suspicious pattern – held for manual analysis |
| Blocked | High risk or restrictive list match – transaction rejected |
| MED notification | Central Bank fraud return mechanism triggered |
Risk classification
Merchants and transactions are classified using a risk-based approach (RBA) :
| Risk Level | Characteristics | Approval | Re-evaluation |
|---|
| Low risk | Standard operations, complete documentation | Compliance Director | Every 24 months |
| Medium risk | Some flags or higher-value operations | Compliance Director | Every 18 months |
| High risk | PEPs, restricted segments, complex structures | Subcommittee approval | Every 12 months |
Suspicious activity reporting (COAF)
Transactions or situations that may indicate money laundering or terrorist financing must be reported to COAF.
Examples of suspicious indicators
| Indicator | Description |
|---|
| Unusual patterns | Frequency or values atypical for the client |
| Resistance to provide information | Client avoids contact or document submission |
| False information | Difficult or costly to verify |
| Incompatible resources | Movement inconsistent with declared income/activity |
| Acting on behalf of third parties | Without revealing beneficial owner |
| Sudden limit increase requests | Without reasonable justification |
⚠️ Suspicious transaction reporting is mandatory. The Compliance team makes final reporting decisions.
Intercompany payment restrictions (BCB Resolution nº 561/2026)
Intercompany payments (where paying and receiving companies share corporate structure) are not permitted under the eFX model.
| Reason | Explanation |
|---|
| eFX purpose | Limited to purchase of goods/services or unilateral transfers |
| Intercompany characterization | May be interpreted as capital transfers or loans – not allowed in eFX |
| Required alternative | Use traditional FX market for intercompany operations |
Compliance training
WEpayments provides regular training on PLD/FTP topics:
| Training type | Frequency | Audience |
|---|
| Awareness training | Annual | All employees |
| Refresher training | As needed | Compliance-relevant roles |
| Educational materials | Ongoing | Employees, partners, suppliers |
