Brazil

Global sanctions guide

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British Virgin Islands
  1. Does Brazil have a sanctions regime in place?

Yes.

  1. Does Brazil implement UN sanctions?

Yes. Brazil implements most sanctions agreed by international bodies, which then become binding on all individuals and entities in Brazil.

  1. Does Brazil implement an autonomous sanctions regime?

No autonomous sanctions regime is implemented by Brazil, but the Brazilian penal code and legislation establish several sanctions to be observed by Brazilian individuals and entities.

  1. What is the nature of the sanctions regime in Brazil?

International sanctions are incorporated into Brazilian law by Presidential decree and, in certain circumstances, legislative acts. These laws are then regulated by the competent state body. The most common measures are embargoes, travel bans on named individuals, and bans on the import and exports of goods and raw materials. Financial sanctions such as asset freezing can only be enforced by court order.

  1. Does Brazil maintain a list of sanctioned individuals and entities?

Yes. Brazil maintains a consolidated list of individuals and entities which are subject to those UN Security Council sanctions implemented into Brazilian legislation by way of Presidential decrees.   These decrees are put together by the Central Bank of Brazil.

  1. Are there any other lists related to sanctions?

Yes. For example, there are lists of entities prevented from participating in public bids.

  1. Does Brazil have a licensing or authorisation system in place?

No.

  1. What are the consequences for a breach of sanctions in Brazil?

Some actions relating to breach of sanctions are criminal offences, for example smuggling and financial crime.

  1. Who are the relevant regulators in Brazil and what are their contact details?

In Brazil there is no governmental body with overall responsibility for sanctions. The following have regulatory powers:

The Ministry of Development, Industry and Foreign Trade is responsible for applying trade sanctions, such as bans and export licences.

EQN 102/103,
Lote 01, Asa Norte,
CEP: 70.722-400 –
Brasília – DF

T: (+55) 61 2027 9217

The Ministry of Finance is responsible, together with the Brazilian Central Bank of Brazil (“BCB”), for implementing and administeringfor financial sanctions in Brazil.  This work is carried out by the Council for Financial Activities Control (“COAF”) and by the Department of  Assets Recovery and International Legal Co-operation (“DRCI”); however freezing of financial and other assets can only be determined by judicial decision.

Department of Assets Recovery and International Legal Co-operation
SCN Quadry 6
Conjunto A
Bloco A
2º andar, Ed. Venâncio 3000, Asa Norte,
CEP 70716-900.

T: (+ 55) (61) 2025 8919
E: cooperacaocivil@mj.gov.br

Council for Financial Activities Control

SAUS Qd 1 Lote 3-A
ZIP Code: 70.070-010 –
Brasilia – DF

T: (+55) (61) 2025-4001 / 2025-4002;
E: coaf@fazenda.gov.br

Contributor law firm

Isabela Faria, L.O Baptista Schmidt, Valois, Miranda, Ferreira, Agel Rua da Assembléia, 66 17º CEP: 20011-000, Rio de Janeiro RJ Brasi