Digital Financial Services

  • The Brazilian National Monetary Council (the “CMN”) issued Resolution No. 4,658 (the “Resolution”), which establishes new cybersecurity requirements covering institutions regulated by the Brazilian Central Bank (Banco Central do Brasil). The Resolution requires covered financial institutions to have cybersecurity policies in place by May 6, 2019, and be fully compliant with the regulation by December 31, 2021. Notably, the Resolution’s requirements cover third-party service providers that contract with covered institutions, including those located outside of Brazil.
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