SUSEP launches public consultation to update rules governing procedures for preventing and combating financial crimes and terrorism

Contribution deadline ends on June 28, 2026

The Superintendence of Private Insurance (SUSEP) launched Public Consultation Notice No. 002/2026 to gather market input on the draft resolution that updates policies, procedures, and internal controls to prevent and combat financial crimes.

The proposed regulatory amendment, published on May 29, 2026, aims to replace Susep Circular No. 612/2020. It consists mainly of formal adjustments and editorial improvements, with no substantial changes to the content. The main goal is to align the regulation with the standards recently enacted for insurance cooperatives and mutual asset protection entities.

Key changes include:

• Extension of the scope (Article 1): The draft includes within its scope the prevention of and the fight against the proliferation of weapons and mass destruction, in addition to financial crimes (money laundering) and terrorism.
• Inclusion of new entities (Article 2): The proposal also extends the application of the rules to insurance cooperatives, administrators of mutual asset protection operations, and client order processing companies (SPOCs), in line with Supplementary Law No. 213/2025 and CNSP Resolutions and 492/2026.
• Update of definitions (Article 3): The draft proposes adjustments aligned with the proposed updates:
  • Change in the regulation’s nomenclature from “circular” to “resolution.”
  • Inclusion of mutual asset protection operations administrators and client order processing companies in the definition of “companies.”
  • Inclusion of “intermediaries of mutual asset protection contracts” within the concept of “insurance brokers”.
  • Inclusion of “individuals participating in mutual asset protection groups” within the concept of “clients and beneficiaries.”
• Details of the responsible officer’s duties (Article 12): The draft includes combating the proliferation of weapons of mass destruction among the items subject to internal controls and prevention procedures that were already under the responsibility of the responsible director, such as financial crimes and terrorism.
• Creation of a list of higher- and lower-risk transactions (Article 50): The proposed regulation allows SUSEP’s general coordination responsible for overseeing practices to prevent money laundering and terrorist financing – currently the General Coordination of Final Matters (CGAFI) – to create a list of transactions classified as higher and lower risk, in order to identify which require enhanced or simplified due diligence.

Interested parties may submit their contributions through the public consultation system by June 28, 2026. In addition, the documents related to the public consultation are available on the SUSEP website and can be accessed via the links provided below:

• Draft of the resolution
• Explanatory memorandum
• Comparative table

Demarest’s Insurance, Reinsurance, Health and Private Pension team is monitoring the matter and remains available to provide any necessary clarifications.