Crossborder Compliance Requirements

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

​Regulatory framework

​Key compliance concepts

​Prevention methods: KYC, KYB, KYP, KYE, KYS

​Required documentation for cross-border payments

​Per transaction

​Onboarding / first transaction

​CBD-specific documentation (if applicable)

​Compliance monitoring and analysis

​What is monitored

​Monitoring outcomes

​Risk classification

​Suspicious activity reporting (COAF)

​Examples of suspicious indicators

​Intercompany payment restrictions (BCB Resolution nº 561/2026)

​Compliance training