Financial Activities Control Council (COAF)


Financial Activities Control Council (COAF)


Recent COAF decisions in two Administrative Sanctioning Processes (“Decisions”), published on June 25, 2024, imposed million-dollar fines on the Brazilian subsidiary of an international conglomerate in the luxury market. The penalty was motivated by non-compliance standards to prevent money laundering and the financing of terrorism and the proliferation of weapons of mass destruction (“AML/CTF”) related to markets for trading luxury or high-value goods and trade in jewelry, stones and precious metals.

The decisions were based on the following infractions, among others:

  • Lack of identification and updating of customer records.
  • Lack of registration of transactions.
  • Failure to report operations involving cash transactions above the established limit.
  • Failure to report suspicious ML/TF operations.
  • Deficient implementation of AML/CTF policies.
In this case, COAF applied fines proportional to the amount of irregular operations and the severity of the failures. The Decisions considered the size of the company and its global operations. Administrators were also held individually responsible, with fines that varied according to the period of management and the severity of the infractions.


The case serves as a warning about the importance of effective implementation of AML/CTF policies, especially by companies that deal with high-value goods, such as the luxury sector. Failure to comply with regulatory standards can result in serious financial and reputational consequences.


Our Compliance, Investigation, and White-Collar practice group is available to assist you and clarify any doubts regarding COAF Resolutions.


Isabel Franco | ifranco@azevedosette.com.br

Viviane Próspero João | vprospero@azevedosette.com.br