Brazil Crypto Report #174: Winners and Losers of Brazil’s New VASP Rules with Carlos Russo and Cesar Carvalho
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Nov 15, 2025 
Carlos Eduardo Russo, CEO of BlueGreen, and Cesar Carvalho, a Partner at Batista Luz Advogados, discuss the groundbreaking VASP regulations in Brazil. They explore the phased authorization process and significant capital requirements, which range between R$11-37 million. The integration of stablecoins into Brazil’s FX market adds a new layer of complexity. They also address concerns about old and new entities competing fairly under the new rules and highlight the implications for neobanks and crypto cards. Their insider insights reveal what’s next for the industry.
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Stablecoins Recognized As FX Tools
- The Central Bank formally recognized stablecoins and crypto as valid tools for cross-border transfers, removing prior regulatory gray zones.
- This validation lets firms operating with stablecoins continue while they apply for authorization, legitimizing an existing business model.
Self‑Custody Allowed But Treated As FX
- The final rules allow transfers to self-custody wallets but classify those transfers as part of the FX market, increasing oversight.
- The bigger risk for users is potential future taxation, not just data leakage, because FX treatment enables IOF moves.
FX Classification Is Broad And Vague
- The central bank folded crypto transactions into FX rules but left some definitions vague, possibly sweeping in more transactions than intended.
- AB Token plans follow-up discussions to narrow which crypto flows truly qualify as FX transactions.