Brazil — Country Risk Report

Brazil (Americas • South America). Risk report as of the 19 Jun 2026 FATF plenary.

Moderate country risk, with elevated corruption risk. Brazil's country risk score is 4.1/10, placing it in the moderate-risk band. The principal driver is weak corruption, alongside rule of law and institutions risk. Brazil is not currently FATF grey- or black-listed. Brazil is not subject to comprehensive country-wide sanctions. Firms should apply additional scrutiny where exposure involves state-linked entities, restricted sectors, sensitive technology, dual-use goods or politically exposed counterparties.

Recommended treatment

Standard due diligence, with enhanced checks for defined risk triggers.

At a glance

  • FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
  • Comprehensive country sanctions: none identified. Targeted sanctions exposure: possible, screen applicable persons, entities and sectors
  • Government effectiveness and rule of law: 4.9/10
  • Corruption (CPI 2025): 35/100, rank #107 of 182
  • Enforcement: 557 actions from 1 regulator

Country Risk Score: 4.1/10 (Moderate)

Higher score means higher country risk (global average 4.6). Full information available. Strong data coverage. Enforcement activity and CPI are shown for context but do not change the score.

All three parts of the score are available.

How this score was calculated

  • Financial crime controls: 5.3/10 — 50% of this score
  • Government effectiveness and rule of law: 4.9/10 — 30% of this score
  • International sanctions: 0.0/10 — 20% of this score

International sanctions contributes 0.0 because the complete UN, UK, EU and US review found no direct country-level sanctions programme. People or organisations connected to the country may still appear on sanctions lists.

Show the exact calculation

aml 5.3 × 50% + governance 4.9 × 30% + sanctions 0 × 20% = 4.1; final 4.1

Principal risk drivers

  • Corruption (WGI) — 6.0/10
  • Rule of law & institutions — 5.1/10

Mitigating factors

  • Not currently on the FATF grey or black list.
  • No comprehensive country-wide sanctions programme.
  • Comparatively stronger voice and accountability (3.8/10).
  • Risk is concentrated in specific counterparties, sectors and transactions rather than applying uniformly.

Business impact

  • Customer onboarding (Medium): Additional ownership and control verification may be required.
  • Payments and transactions (Medium): Review transaction purpose, counterparties and geographic routing.
  • Trade and export activity (Medium): Screen goods, end users and potential dual-use exposure.
  • Corporate clients (Medium): Assess state ownership, government links and political exposure.
  • Ongoing monitoring (Medium): Apply alerts for ownership changes, sanctions and geopolitical developments.

Recommended controls

  • Verify ultimate beneficial ownership using more than one reliable source.
  • Identify state ownership, government influence and politically exposed persons.
  • Screen entities, directors and beneficial owners against applicable sanctions lists.
  • Apply enhanced review to technology, defence, telecommunications, financial services and dual-use activity.
  • Document transaction purpose and source of funds where cross-border structures are complex.
  • Escalate unresolved ownership opacity or adverse information to Compliance.

Enhanced due diligence triggers

  • State ownership / control
  • PEP involvement
  • Sensitive / restricted sectors
  • Opaque ownership
  • Adverse media
  • Dual-use goods & technology
  • High-risk intermediary routing

FATF status: Not currently listed

Brazil is not on the FATF grey or black list as of the 19 Jun 2026 plenary.

Source details

International sanctions by issuing body

  • UN: No
  • EU: No
  • UK: No
  • US: No

No means the complete UN, UK, EU and US review found no direct country-level programme. People or organisations may still appear on sanctions lists.

Government effectiveness and rule of law (World Bank 2024, percentile)

  • Government Effectiveness: 47/100
  • Regulatory Quality: 50/100
  • Rule of Law: 49/100

Enforcement activity

RegActions tracks 557 enforcement actions from 1 regulator in Brazil.

The composite RegActions Country Risk Score does not use enforcement volume.

Regulators and legal framework

FATF network

FATF member.

Last mutual evaluation: 2023 · report

National regulators

FIU: Egmont Group member (COAF)

Framework signals

  • FATF listing: Not currently listed
  • International sanctions: no listed programme identified
  • BO register: Restricted (live since 2017)
  • Corruption (CPI 2025): 35/100, rank #107 of 182
  • Rule of law (WGI): 5.1/10 risk

Sector exposure

  • Banking & payments (Low): No FATF listing, rule-of-law governance within normal range
  • Trade & export controls (Low): No sanctions programme or FATF black-list constraint identified
  • Crypto & virtual assets (Low): No FATF listing, accountability governance within normal range
  • Real estate & luxury assets (Elevated): Elevated corruption exposure (CPI 35/100)
  • State-linked & procurement (Elevated): State-capture exposure (corruption WGI 6.0/10)

Derived from sanctions tier, FATF listing, World Bank WGI governance and CPI; no per-sector dataset is asserted.

Brazil: analysis

Brazil's profile is driven entirely by its governance indicators; it is not FATF-listed and no sanctions apply. The weakest domain is corruption (weighted 35%), followed by rule of law and institutions (weighted 40%). These are partially tempered by voice and accountability (weighted 10%) and political stability (weighted 15%), both of which are relatively strong and reflect functioning democratic and governmental institutions. The CVM's 557 enforcement actions between 2021 and 2026 from a single regulator indicate active supervisory engagement. The CPI reading is consistent with a persistently elevated corruption environment.

Outlook

Brazil's risk profile is sensitive to the effectiveness of its anti-corruption institutions and the trajectory of political accountability. The CVM's active enforcement posture is a positive indicator of supervisory capacity. Further erosion of institutional independence or backsliding on anti-corruption commitments would be likely to weaken the governance picture. No FATF listing or sanctions currently apply, and maintaining this position depends on continued AML/CFT framework compliance.

Key watchpoints

  • CVM enforcement activity trends as an indicator of both supervisory capacity and the level of underlying financial market misconduct.
  • Annual WGI revisions to the corruption and rule of law domains, which together carry 75% of the governance weighting.
  • October 2026 FATF plenary for any change in listing status.
  • Domestic political developments affecting the independence of anti-corruption and financial regulatory bodies.

Assessment currency

  • FATF status: Not listed (as of 19 Jun 2026)
  • Sanctions exposure: None identified (as of Jul 2026)
  • Governance (WGI): Latest dataset incorporated (as of 2024)
  • Corruption (CPI): 35/100 (as of 2025)
  • RegActions assessment: Reviewed (as of 19 Jun 2026)

Public evidence layer

FATF action: none. No FATF call-for-action or increased-monitoring status was identified at the latest plenary. This does not establish low risk.

Contextual signals (not scored)

  • FATF network membership: Direct FATF member (present, as of 2026-07)
  • EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
  • Egmont Group FIU: COAF (present, as of 2026-07-17)
  • Beneficial-ownership register: Restricted (live since 2017) (present, as of 2026-07-17)
  • Transparency International CPI: 35/100, rank 107 (present, as of 2025)

Evidence freshness

  • FATF monitored-jurisdiction status: current; data 2026-06-19
  • FATF mutual evaluation and follow-up ratings: current; data 2026-07-31; follow-up 2023-12; base assessment 2023-12
  • World Bank governance indicators: current; data 2024
  • UN, UK, EU and US sanctions regimes: current; data 2026-08-13

Contextual signals are public evidence only and do not change the immutable v2 score.

Download evidence PDF · CSV · JSON

Regional peer scores

FAQ

Is Brazil on the FATF grey list?

No. Brazil is not on the FATF grey or black list as of the 19 Jun 2026 plenary. FATF listing is one AML indicator; absence from the list does not by itself make Brazil low risk. The next FATF plenary review is scheduled for Oct 2026.

Is Brazil subject to sanctions?

No country-level programme was identified. In the approved RegActions snapshot, no comprehensive or targeted country-wide sanctions programme was found for Brazil, but individual listed persons may still exist, so firms should continue to screen counterparties against the applicable lists.

What is Brazil's country risk rating?

RegActions rates Brazil at 4.1/10 (Moderate risk), where a higher score means higher country risk. The score combines financial crime controls, government effectiveness and rule of law, and international sanctions. Transparency International's 2025 Corruption Perceptions Index scores Brazil 35/100 (rank #107 of 182).

What due diligence applies to Brazil?

Standard due diligence, with enhanced checks for defined risk triggers. This is decision-support based on Brazil's FATF status, governance and sanctions signals, and is not a substitute for a firm's own risk assessment.

How much enforcement activity is tracked for Brazil?

RegActions tracks 557 enforcement actions from 1 regulator in Brazil. Enforcement volume measures regulator activity, not country risk, so it is shown as evidence but never fed into the RegActions Country Risk Score.

Source: FATF black & grey lists · World Bank WGI (CC BY 4.0 — World Bank WGI) · TI CPI (CC BY-ND 4.0 — Transparency International, display only)