COAF applies fines for the omission of suspicious transactions


COAF applies fines for the omission of suspicious transactions


The Financial Activities Control Council (“COAF”), the agency responsible for monitoring and preventing money laundering practices, applied fines totaling BRL 55.7 million to companies operating in the financial and luxury sectors throughout 2024. These sanctions were motivated by the omission of information on suspicious financial transactions, representing a significant increase of 66% compared to the fines applied in the previous year, which totaled BRL33.5 million.

The largest fine, BRL 20 million, was applied to a company headquartered in São Paulo that specializes in outsourced financial management. The penalty was due to the omission of information on suspicious transactions totaling BRL 4.3 billion.

Another significant fine, BRL 5 million, was directed at a famous company in the luxury goods segment. The sanction was motivated by failures to report financial transactions carried out in cash, which exceeded the limit stipulated by COAF, and by failure to comply with the agencys requests for information. The companys representatives, both in Brazil and abroad, were also individually penalized.

A luxury vehicle dealership in Brasília was fined BRL 5 million for irregularities such as the lack of updated customer records, the omission of information on suspicious transactions, and the failure to implement effective policies to prevent money laundering. The case also involved records of inconsistencies in documents and financial transactions identified in previous investigations.

Linked to the Brazilian Ministry of Finance, COAF plays an essential role in preparing financial intelligence reports on suspicious transactions, including movements of large amounts of cash. These reports are forwarded to the police authorities and the Public Prosecutors’ Office for support in criminal investigations. The information that makes up the reports is provided by regulated agents, such as financial institutions, notary offices, vehicle dealerships, and jewelry stores, as established by Law 9.613/1998.

In addition to its financial intelligence function, COAF is also responsible for judging and applying sanctions to companies that fail to report suspicious transactions. The fines applied generally represent a percentage of the value of the omitted transactions. Penalized companies have the right to appeal to the National Financial System Appeals Council, linked to the Ministry of Finance, which acts as a second instance in administrative proceedings.

Compliance with Anti-Money Laundering (AML) regulations is essential to avoid financial sanctions and protect companies reputations. We reinforce the importance of maintaining rigorous processes for identifying customers, monitoring transactions, and reporting atypical operations.


Our Compliance, Investigation, and White-Collar practice group is available to assist you, clarify any questions, and assist penalized companies in bringing appeals before the National Financial System Appeals Council.


Isabel Franco: ifranco@azevedosette.com.br

Glaucia Ferreira: gferreira@azevedosette.com.br

Julia Wolff: jwolff@azevedosette.com.br