Banks, Financial Services, Fintechs and Digital Assets Newsletter – February 2026

In this edition of our monthly newsletter, we have compiled the main news and regulatory developments regarding the banking industry, financial services, fintechs, and digital assets.  This publication was designed as a reliable source of information for our clients, partners and professionals who work or want to know more about the current landscape in regard to these topics.

Enjoy reading!

Regulations

Central Bank of Brazil

BCB Normative Instruction (“IN”) No. 713, dated February 27, 2026

IN BCB No. 713 establishes the procedures for submitting information to the Central Bank of Brazil regarding the provision of virtual asset services set out in Article 88, item III, subitems “b,” “c,” “d,” and “e” of BCB Resolution No. 520, dated November 10, 2025.

These provisions apply to virtual asset service providers (VASPs) that, on the date BCB Resolution No. 520/2025 entered into force, were carrying out one or more of the activities listed in Article 7, head section and subparagraphs, and in Article 9, head section and subparagraphs, of that resolution.

BCB IN No. 713 entered into force on the date of its publication.

Read BCB IN No. 713 in full.

News

Central Bank decrees extrajudicial liquidation of Banco Pleno and Pleno DTVM

On February 28, the Central Bank decreed the extrajudicial liquidation of Banco Pleno S.A., extending the special bankruptcy regime to Pleno Distribuidora Títulos e Valores Mobiliário S.A., a small conglomerate classified under the S4 segment of prudential regulation, with Banco Pleno as its leading institution.

The liquidation was driven by the institution’s compromised financial condition and liquidity deterioration, violations against the rules governing its activities, and failure to comply with the Central Bank’s determinations.

The investigation results may lead to administrative sanctions and referrals to competent authorities, as established by law. Under the terms of the law, the assets of the controlling shareholders and the administrators of the institution subject to the decreed liquidation are rendered unavailable

Read the Central Bank’s article in full

Filing of the Annual Declaration of Brazilian Capital Held Abroad (“DCBE”) begins; deadline is April 6

The Annual Report of Brazilian Capital held Abroad (“DCBE”) regarding the base date of December 31, 2025, must be submitted to the BC by April 06, 2026.

The annual declaration must be submitted by all individuals and legal entities that:

• Are residents, domiciled or headquartered in Brazil; and
• Held, outside Brazil, amounts, property, rights and assets of any nature amounting to USD 1 million or more (or the equivalent in other currencies) on December 31, 2025.

The DCBE must include assets, rights and values held abroad consisting of:

1. Equity interests in non‑resident entities;
2. Brazilian Depositary Receipts (BDRs) of securities issued by companies headquartered abroad;
3. Shares or units of offshore investment funds;
4. Debt securities issued by non‑residents;
5. Loans and financing granted to non-residents;
6. Deposits with non-resident institutions;
7. Trade receivables against non-residents;
8. Real estate located abroad;
9. Virtual assets held on foreign exchanges or wallets;
10. Derivatives traded abroad; and
11. Export revenues held abroad, among others.

Failure to provide required information, providing false, incomplete or incorrect information, or filing outside statutory deadlines and conditions constitutes an infraction subject to penalties by the Central Bank.

The Central Bank must process submitted data confidentially, that is, without identifying individual situations.

Read our client alert on this topic.

Central Bank makes UNICAD registration mandatory for virtual asset services

Published on February 27, 2026 by the Central Bank, BCB IN No. 712 amends BCB IN No. 330, dated November 24, 2022, which establishes procedures for registering information in the Central Bank’s Information System on Entities of Interest (UNICAD), pursuant to BCB Resolution No. 209, dated March 22, 2022.

BCB IN No. 712 implements the mandatory registration of activities involving virtual assets in UNICAD, expanding the Central Bank’s oversight capacity over the crypto-asset ecosystem, ensuring greater visibility, standardizing procedures, and promoting transparency in transactions.

Central Bank expands Brazil’s regulatory framework for virtual assets

On February 26, 2026, the Central Bank published two resolutions of the National Monetary Council (CMN):

• CMN Resolution No. 5,280: Brings VASPs within the scope of Supplementary Law No. 105, dated January 10, 2001, which provides for the confidentiality of financial institution transactions, among other measures.
• CMN Resolution No. 5,281: Establishes criteria that financial institutions and others authorized to operate by the Central Bank must follow in the recognition, measurement, and accounting disclosure of virtual assets.

On the same day, the Central Bank also published BCB Resolution No. 550, which establishes criteria for consortium administrators, payment institutions, securities brokerage firms, securities distribution companies, foreign exchange brokerage firms, and VASPs for the recognition, measurement, and accounting disclosure of virtual assets.

The three standards form a comprehensive regulatory framework for the handling of virtual assets in Brazil, covering confidentiality, accounting, transparency, and governance.

Master and Will Bank clients claim that Bank of Brasília recorded settled or non‑existent debts with the Central Bank

Clients who took out loans or financial services with Will Bank or Banco Master reported finding debts registered as active or overdue in the Central Bank’s Credit Information System (SCR), even though many had already been settled or did not exist. According to reports, the Bank of Brasília (BRB) is responsible for the entries.

The situation is linked to BRB’s purchases of credit portfolios from Master since 2024. The BRB announced an agreement to acquire Master in March 2025, but the Central Bank vetoed the BRL 2 billion transaction in September 2025.

After Master’s extrajudicial liquidation, the Federal Police began investigating a billion-dollar fraud scheme involving the sale of approximately BRL 12 billion in low-quality, unsecured credit portfolios to BRB. As compensation for previously transferred problematic portfolios, Master assigned new portfolios to BRB, including assets originating from Will Bank.

According to Fabio Braga, partner in Demarest’s Banking and Finance practice, it is common for banks and financial institutions to sell, transfer, or assign portfolios as part of their negotiations. Braga also remarks on the strategic decisions involved: “Banks discuss the structure of these contracts and the costs involved. For how much will I sell, and what discount will I offer? Another important point is that the negotiation also defines who will be responsible for managing payments.”

Read the G1 article in full

Card schemes become responsible for passing on the full purchase amount to merchants

Under the Central Bank’s new regulation, card schemes (bandeiras) are now responsible for the full settlement of transactions and payments to merchants, reinforcing the need for more robust guarantee mechanisms and risk controls.

As a result, acquirers and sub‑acquirers may not allocate risks to card schemes. They must meet each scheme’s specific requirements, which could increase costs and complicate operations for smaller businesses. While the market acknowledges that these changes enhance security, they also require significant investment in technology, compliance and process standardization.

In this landscape, the Pix Parcelado scheme (a new feature within Brazil’s instant payment system that allows users to pay for purchases in installments) emerges as a modality that can increase the volume of transactions under the card schemes’ responsibility, although further regulation is still required. The prevailing opinion is that this feature will coexist with credit cards, but will require clear rules for direct‑to‑consumer credit transactions.

According to Fabio Braga, partner in Demarest’s Banking and Finance practice: “Pix Parcelado has a place in the market and does not threaten the leadership of credit cards, but it will need to be better developed, with clear rules for those who offer credit directly to consumers and for charging interest.”

Read the Valor Econômico article in full

Tokens poised to reshape the credit ecosystem

The recent regulation of the cryptoasset market has consolidated the Central Bank as the central authority in the sector, providing clear legal bases for service providers and creating room for the expansion of tokenization.

This advance strengthens the regulatory framework for transforming real assets into digital tokens, increasing traceability, reducing operational risks, and accelerating transaction settlement.

The integration of tokenization and open finance enables institutions to cross-reference transactional data with programmable contracts, resulting in safer, personalized, and real-time-monitored financial products. Within this context, Marcus Fonseca, partner in Demarest’s Banking and Finance practice, notes that tokenization reduces information asymmetry and enables reliable data flows that benefit several stages of the chain, thus improving the use of the asset as collateral.

The consolidation of this ecosystem also depends on the regulation of stablecoins and a technical infrastructure capable of integrating digital and traditional transactions. Pilot projects are already under development to simulate the full life cycle of tokenized assets, from issuance to settlement, with the aim of reducing costs, increasing transparency, and standardizing procedures. Recent efforts have involved large financial institutions and market entities, demonstrating that tokenization is likely to become a structural component of the financial system.

Read the Valor Econômico article in full