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ARTICLE · 26 OCTOBER 2026

Susep Updates Its AML/CFT Rules And Modernizes Its Internal Procedures For Reporting To COAF

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Brazil's insurance regulator has introduced comprehensive updates to anti-money laundering and counter-terrorism financing rules, establishing a new three-tiered due diligence framework and expanding regulatory oversight. The changes, effective January 2027, require supervised entities to reassess their compliance programs and internal controls to align with stricter risk management standards.

BrazilFinance and Banking

On October 1, 2026, the Brazilian Superintendence of Private Insurance (“Susep”) published Susep Resolution No. 99/2026 (“Resolution”), which replaces Susep Circular No. 612/2020. The new Resolution, which will enter into force on January 1, 2027, updates the rules governing policies, procedures, and internal controls to prevent and combat money laundering and the financing of terrorism and of the proliferation of weapons of mass destruction (“AML/CFT”).
While preserving the pillars already established under Susep Circular No. 612/2020, the Resolution introduces significant changes to risk management, due diligence procedures, and the obligations applicable to supervised entities.

The Resolution expands its scope to expressly cover insurance cooperatives, administrators of mutual protection operations, and customer order processing companies.

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