Law No. 15,358/2026 introduced significant amendments to Brazil’s Anti-Money Laundering Law and Fixed-Odds Betting Law, expanding the obligations of financial institutions, payment institutions, fintechs and authorized betting operators in relation to anti-money laundering (AML), transaction monitoring and compliance with account-freezing orders.

The changes require stronger customer identification and monitoring procedures, a review of internal controls, and the implementation of mechanisms capable of ensuring timely compliance with orders from the competent authorities. In practice, that means closer coordination among legal, compliance, technology and operations teams, along with a fresh look at internal workflows so that responses are prompt and properly documented.

Beyond expanding regulatory obligations, the law casts these institutions more firmly as front-line actors in preventing and combating money laundering and the financing of criminal organizations. Governance frameworks, internal controls and monitoring mechanisms therefore stop being mere compliance best practices and become strategic tools for mitigating legal and operational risks.

The amendments also make it more urgent to review governance frameworks and internal protocols for prevention, monitoring and incident response, particularly given heightened scrutiny of the conduct of officers, directors and the professionals responsible for compliance and AML functions across all four categories of institution.

An increased penalty now applies to anyone who, by any means, transfers abroad all or part of the proceeds or benefits of a criminal offense, or provides or raises funds, assets, rights, monies, services or information to finance, in whole or in part, an ultraviolent criminal organization.

The challenge is not only adapting to new domestic legislation. Companies must also get ahead of the still-uncertain expectations of global investors and business partners, who are likely to adopt more stringent due diligence and risk-management standards for third parties and operating chains that they may, at their own discretion, treat as connected to businesses moving funds, monies and assets in Brazil.