Circular 2020
Circular SUSEP nº 612, de 18 de agosto de 2020 (SUSEP Circular 612 on AML/CFT policies, procedures and internal controls)
Issued by Superintendência de Seguros Privados
Effective: 1 Mar 2021
Plain-English summary
Sets AML/CFT controls for insurers, capitalisation companies, reinsurers, open pension entities and insurance brokers supervised by SUSEP. It requires a responsible director (Art. 12), customer due diligence (Arts. 16–30), reporting to COAF within 24 hours of concluding the analysis (Art. 35 §2) and an annual effectiveness report by 31 March (Art. 41 §2). SUSEP says it is to be revoked on 1 January 2027 by Resolution SUSEP 99/2026.
Who it applies to
Insurance
Topics
AML / CFT / Sanctions Insurance & Pensions
Obligations arising from this law or regulation
| Obligation | Timing | Regulator | Source | Detail |
|---|---|---|---|---|
| Annual AML/CFT effectiveness report (insurance sector) | Frequency Annually: base date 31 December, delivered by 31 March | SUSEP | source | |
Art. 41 §2 requires an annual effectiveness report with a 31 December base date, delivered by 31 March of the following year. Art. 37 requires a negative communication to SUSEP by the last business day of March if no reportable transactions occurred in the prior year. Art. 15, III requires the internal risk assessment to be reviewed every two years. |
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| Suspicious transaction reporting to COAF (insurance sector) | Deadline Within 24 hours of concluding the analysis | SUSEP | source | |
Art. 35 §2 requires results to be reported to COAF within 24 hours of concluding the analysis or of learning of the qualifying condition. Art. 35 §5 requires automatic reporting of cash transactions of R$10,000 or more and foreign payments of R$100,000 or more. The circular is to be replaced by Resolution SUSEP 99/2026 from 1 January 2027. |
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| No obligations match these filters. | ||||
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