International transfers in a Brazilian app are offered only through an institution the Central Bank of Brazil (BCB) has authorized: a bank, a foreign exchange broker, or a payment institution providing eFX, the international payment service defined in Resolution BCB 277/2022. The app is either that provider or its customer-facing front end, and that choice sets every duty below.
Who can move money abroad for a Brazilian app's users?
Law 14.286 of December 29, 2021 reserves foreign exchange operations for institutions the BCB has authorized (Art. 3). It makes that institution responsible for identifying and qualifying its clients and for processing each operation lawfully (Art. 4, first and second items). Resolution BCB 277 of December 31, 2022 turns the rule into four routes for an app.
Four ways a Brazilian app can offer international transfers, by what the app is and what it answers for
Route | The app is | Authorization that covers the transfer | What the app carries |
A | An FX institution | Its own BCB authorization to operate in the FX market | Client identification and lawful processing of each operation |
B | Its own eFX provider | A listed financial institution, or a payment institution that issues e-money, issues post-paid instruments or acquires | Client disclosures, statements, a contract with the foreign counterparty, reporting, the ten-year record (Art. 50-C) |
C | The front end of a partner's eFX service | The partner's, because the sender in Brazil must be the provider's client | Brand, screens, sender onboarding |
D | The front end of a virtual asset provider doing the payment | The provider's authorization as a virtual asset service provider | The purpose and foreign-party data the provider must collect |
Resolution BCB 561 of April 30, 2026 rewrote the eFX chapter from October 1, 2026. An institution already authorized had to register eFX in the BCB's Unicad system by October 30, 2026 (Art. 56-A). A provider outside the Article 49 list may keep going only if it asks the BCB for payment institution authorization by May 31, 2027, and it must stop thirty days after that date if it did not file (Art. 56-B and §3). What that authorization takes is in neobank license in Brazil.
On Lumx, the Brazilian entity (Lumx Sociedade Prestadora de Serviços de Ativos Virtuais Ltda) acts as a VASP (virtual asset service provider, the FATF term), has filed its authorization request with the BCB and operates under the transition regime of Resolution BCB 520/2025, Art. 88, and is not a bank or a payment institution. Which of routes A to D an app needs in its chain is a question for counsel before launch.
What eFX covers, and where the US$10,000 line sits
Article 49 lists what an eFX provider may do for a client, and most of it stops at US$10,000 per operation. Splitting a transfer to stay under the line is not allowed (§1).
What eFX covers under Resolution BCB 277, Art. 49, and the ceiling on each operation
Operation | Ceiling |
Buying goods and services through the provider's digital payment solution | None if integrated with an e-commerce platform, US$10,000 if not |
Unilateral transfer (a transfer with nothing bought in return) | US$10,000 |
Transfer between the user's own accounts in Brazil and abroad | US$10,000 |
Transfer for financial or securities market investment (added October 1, 2026) | US$10,000 |
A family transfer is a unilateral transfer.
Article 54-A, added by Resolution 561, lets the provider take reais from the sender only through an account in the sender's name, through a boleto (a Brazilian bank slip payable at any bank or app) with the sender as payer, or through a prepaid instrument capped at R$1,000 with no reload. A payment account counts if its institution joined Pix (Brazil's instant payment system, run by the Central Bank).
On Lumx, a standard-verification individual can move $7,500 per transaction and $15,000 per day or month by default, and an enhanced-verification individual starts at $25,000 or more per transaction. A transaction over a limit is rejected, and a higher limit goes through a request.
What must the app tell the user, and what must the user declare?
The provider must tell the client, clearly and in time, what it is responsible for, the service conditions and the client's rights under the payment instrument used, and be able to prove the client agreed (Art. 51). The client then gets a statement of each operation (Art. 52) and classifies the purpose of the operation, with the institution giving guidance when asked (Law 14.286, Art. 4, §§ 2 and 3).
What the send-money screen and the statement must carry, and the norm behind each item
Item | When | Source |
The provider's responsibilities, the service and its conditions, the user's rights under the payment instrument | Before the user pays | Resolution BCB 277, Art. 51, items 1 to 3 |
Proof the user knew and agreed | Kept by the provider | Art. 51, sole paragraph |
Operation, date, parties, amount in reais, fee | On the statement | Art. 52 |
Foreign currency and its amount | On the statement | Art. 52, sole paragraph |
Purpose of the operation | Declared by the user | Law 14.286, Art. 4, §2 |
IOF (the federal tax on foreign exchange operations) | Its own line | Decree 6.306/2007 |
On the virtual asset route, the provider must also collect the purpose in the BCB's codes, the data on the payer or recipient abroad and their link to the client (Art. 76-C, in force from May 4, 2026).
On Lumx, every on-ramp and off-ramp takes a purpose field with one of nine values, among them PERSONAL_ACCOUNT, TRADE_TRANSACTIONS and PROFESSIONAL_SERVICES, and a mismatch with the real activity can trigger an RFI (request for information, a compliance hold that asks for a document before a transaction clears). A P2P remittance takes BILLS, or PERSONAL_ACCOUNT when the user sends to themselves, and the field is separate from the BCB's own classification codes, which the regulated institution collects. Each recipient is a destination under the sender with a declared relationship, such as RELATIVE or FRIEND.
How the rate and the tax reach the user's screen
The rate is free. Law 14.286 says the exchange rate is agreed freely between authorized institutions and their clients, and sets no value limit on foreign exchange operations as such (Art. 2).
IOF is the part that moves. Decree 6.306/2007 regulates it, and Article 15-B sets the rate for each type of foreign exchange operation. No current text of it could be read from a primary source that serves text, so this post states no rate. The app should take the rate for its operation type from the current article and show it as its own line.
Illustrative US$500 send with made-up numbers, showing the lines a user needs to see
Line | Value |
Amount the recipient gets | US$500.00 |
Exchange rate | R$5.0000 per US$1 |
Value in reais | R$2,500.00 |
App fee | R$12.50 |
IOF | Rate for the operation type in Decree 6.306/2007, Art. 15-B, on the day |
Funding source | The user's own account, by Pix |
On Lumx, BRL to USDC is regulated by Resolution BCB 521: it is an operation of the FX market, but it is not a foreign exchange operation, and no IOF applies because a stablecoin is not foreign currency. The Brazilian entity only offers named accounts in BRL, and what enters or leaves it is BRL or a stablecoin. An exchange rate is either floating (a reference rate with no lock) or locked for 30 seconds, one minute or five minutes, and a locked quote can fix the target amount, so an app can fix what the recipient gets. Pix settles at any hour of any day, and a USD payout over FEDWIRE (the Federal Reserve's same-day wire system) or SWIFT has a 3:00 PM Eastern cut-off.
Identification, anti-money-laundering and the foreign counterparty
Law 14.286 puts client identification on the authorized institution, with measures against money laundering under Law 9.613/1998 (Art. 4, first item and §1). Resolution 561 adds the foreign side: the provider must hold a contract with the counterparty abroad and apply the know-your-customer procedures of BCB Circular 3.978 of January 23, 2020 to it (Art. 50-B, second item). Records are kept for ten years (Art. 50-C).
The recipient abroad is checked too. The stablecoin AML guide covers those controls on a stablecoin flow, and what KYB is the company side.
On Lumx, a sender accepts the Terms of Service and completes KYC (know your customer) through Sumsub before moving funds, with the CPF (the Brazilian individual taxpayer ID) as the tax identifier. Chainalysis monitors the stablecoin leg, and a flagged transaction is held while compliance asks for the relationship between sender and receiver, the purpose and the expected outcome, and it may be refunded to the sender if nobody answers within 24 hours. A transfer to an external wallet is identified and reported to COAF (Brazil's financial intelligence unit) as the rules require, Lumx asks Brazilian customers about self-custody on that transfer, and any hold runs as a transactional RFI.
Where stablecoins fit after Resolution 561/2026
Resolution 561 bars virtual assets from the eFX cycle and leaves the virtual asset route standing. Article 50, first item says the payment between the eFX provider and its counterparty abroad runs only through an FX operation or a movement in a non-resident's reais account in Brazil, with virtual assets prohibited. Article 76-A, first item, from Resolution BCB 521 of November 10, 2025, separately counts a payment or transfer with virtual assets as a service inside the FX market for virtual asset providers. The rule the press got wrong and the remittance reading cover how the press read this one text.
Article 76-A has a limit that matters for apps. Moving funds in the interest of a third party through a virtual asset service is forbidden, unless the provider serves an FX-authorized institution that acts for its own clients (§3). Whether a flow fits depends on who the client of record is at each leg. The PSAV explainer and the regulation guide hold the virtual asset layer.
On Lumx, BRL converts to USDC and USDT on Ethereum, Polygon and Base (USDT also on Tron), with Stellar listed as on-ramp only. The stablecoin sits in the sender's custodial wallet.
I recommend that a Brazilian app settle which institution is the eFX provider, in writing, before it designs the send screen, and then build the statement from Article 52 before it builds the price. Before signing I would ask whether eFX is registered in Unicad under the provider's name, who holds the contract with the foreign counterparty, and where the proof of the user's agreement is stored.
When an app should not add international transfers
Do not add them while "who is the provider?" has no contract behind it, when the typical user sends more than US$10,000 at once, or when users expect to fund it from someone else's account.
What this looks like on Lumx for a Brazilian app
Lumx is stablecoin payments infrastructure for businesses that move money between Latin America and the rest of the world: one API to collect, hold, convert, and pay out in BRL, MXN, COP, USD, EUR, and GBP or in USDC and USDT, over local rails such as PIX, SPEI, PSE, Bre-B, ACH, FEDWIRE, SEPA, and Faster Payments, with SWIFT and on-behalf-of payments and collections (POBO and COBO) in USD, EUR, and GBP, plus named virtual accounts, custodial wallets, and KYB/KYC built in.
The app creates each sender as an individual customer with a BRL account, provisioned right after approval. A named virtual account is a local account number issued in the customer's own name. The sender funds the wallet by Pix against an on-ramp created in advance for the exact amount, or through a standing autoconversion rule.
To send, the app registers the recipient as a destination under the sender and calls the off-ramp with a purpose. USD goes out over ACH, FEDWIRE or SWIFT, EUR over SEPA, GBP over Faster Payments (the UK's real-time bank transfer network) and MXN over SPEI (Mexico's interbank transfer system, run by Banxico). A payout over SPEI goes out in the customer's name. The reverse is in USDC to a Brazilian bank account.
The flow pays a third party abroad, so it touches route D and the Article 76-A, §3 limit above. Which route it sits on is the app's decision with its counsel. What Lumx does not do is stand in for the app in front of the BCB. The operator map shows which entity handles which step, supported countries lists where Lumx onboards, and the coverage page lists rails. The global payments page gives the product view.
Methodology and sources
Resolution BCB 277/2022 in its current text, with the changes from Resolutions BCB 561/2026 and 521/2025, was read on November 1, 2026 from the BCB's normative search at normativos.bcb.gov.br, because the pages on bcb.gov.br return only a JavaScript shell. Law 14.286/2021 was read in its original publication on the Câmara dos Deputados site. Decree 6.306/2007 was not read in its current text, so no IOF rate is given, and Law 9.613/1998 and BCB Circular 3.978 of January 23, 2020 are cited by number and date. Lumx's product statements come from the docs on remittances, exchange rates, transaction limits, RFI and cut-offs.
Verified on November 1, 2026. Operational context, not legal, tax, or investment advice.
Cover photo: Phil Hearing on Unsplash.
How can a Brazilian app offer international transfers?
Through an institution the Central Bank of Brazil has authorized: the app is itself an FX institution or an eFX provider, or the front end of a partner that is, with its users as the partner's clients. Resolution BCB 277/2022 sets the eFX rules, as rewritten by Resolution BCB 561/2026 from October 1, 2026. On Lumx, the choice of regulated partner stays with the app.
What is eFX and what is its limit?
eFX is the international payment or transfer service in Title V of Resolution BCB 277/2022. Most of its operations stop at US$10,000 per operation, including unilateral transfers and transfers between a user's own accounts, and splitting is not allowed. On Lumx, a standard-verification individual has a default limit of $7,500 per transaction.
What must a Brazilian app show the user before an international transfer?
The provider must inform the client in time of its responsibilities, the service conditions and the client's rights under the payment instrument, and prove the client agreed. The statement then shows the date, the parties, the amount in reais, the fee and the foreign-currency amount. On Lumx, a locked quote holds for up to five minutes.
Can an international transfer from a Brazilian app settle in USDC?
Not inside the eFX cycle, where Resolution BCB 561/2026 prohibits virtual assets between the provider and its foreign counterparty. A payment with virtual assets is a separate service under Article 76-A, for virtual asset providers. On Lumx, BRL converts to USDC and USDT, and the Brazilian entity operates as a VASP under the Article 88 transition regime.
Does IOF apply to international transfers from a Brazilian app?
IOF is the federal tax on foreign exchange operations, and Article 15-B of Decree 6.306/2007 sets the rate for each type. No current rate was read for this post, so the app should take it from the current article and show IOF as its own line. On Lumx, BRL to USDC carries no IOF, as above, and a locked quote returns the rate and final amounts for the lock period, so the amounts on the screen hold while the user confirms.
