Susep Updates Its AML/CFT Rules And Modernizes Its Internal Procedures For Reporting To COAF

On October 1, 2026, the Brazilian Superintendence of Private Insurance (“Susep”) published Susep Resolution No. 99/2026 (“Resolution”), which replaces Susep Circular No. 612/2020. The new Resolution, which will enter into force on January 1, 2027, updates the rules governing policies, procedures, and internal controls to prevent and combat money laundering and the financing of terrorism and of the proliferation of weapons of mass destruction (“AML/CFT”).
While preserving the pillars already established under Susep Circular No. 612/2020, the Resolution introduces significant changes to risk management, due diligence procedures, and the obligations applicable to supervised entities.

The Resolution expands its scope to expressly cover insurance cooperatives, administrators of mutual protection operations, and customer order processing companies.

It also establishes a three-tiered due diligence process with the applicable tier determined by an internal risk assessment. For higher-risk situations, the Resolution expressly requires stricter measures. Supervised entities will therefore need to review their routine verification procedures to ensure compliance with the new regulatory framework.

Another relevant change is the formal inclusion of the financing of the proliferation of weapons of mass destruction within the regulatory scope. Although Susep notes that the risk management and control mechanisms under Susep Circular No. 612/2020 were already expected to address relevant risks even when not expressly identified, the new wording removes any doubt that this risk must be accounted for in AML/CFT programs. The new rules also update customer identification and qualification procedures and expressly allow supervised entities, subject to the applicable requirements, to rely on customer identification, qualification, and risk classification procedures carried out by institutions within the same conglomerate or cooperative system.
In parallel, Susep’s Normative Ruling No. 40/2026 replaces Susep Normative Ruling No. 75/2015 and updates its own internal procedures for reviewing and forwarding reports of suspicious transactions and situations to COAF. The new framework adapts the process to the electronic environment, with dedicated and confidential proceedings, centralized documentation, and the participation of the Integrated Supervision Committee in the review of such reports. These measures aim to increase the security and efficiency of the process.

Supervised entities should assess whether their policies, procedures, and controls align with the new requirements. With the Resolution taking effect on January 1, 2027, entities should take the opportunity to review their AML/CFT frameworks and anticipate any updates that may be necessary.