In the previous issue, Brazil appeared with a timeline. In this one, it appears with a result — and the result contradicts the easiest reading.
On October 30, the deadline expired for virtual asset service providers already in operation to file their authorization request with the Central Bank of Brazil (BCB). Much of the market expected an exodus. In terms of volume, the opposite happened: an independent survey by Cainvest, compiled from public sources, reached about 74 companies across requests, registrations and regulatory filings, and, according to Bitnotícias, the BCB received around 852 documents on October 30 alone, for a total of roughly 4,311 over the month.
What changed was not the size — it was the composition. Among the names in the survey are Binance, Coinbase, Bybit, OKX, Bitget, Kraken, Ripple, Mercado Bitcoin, Foxbit, Ripio, Brasil Bitcoin, Itaú, Bradesco, Nubank, Banco Inter, B3 and BTG Pactual. Large banks, the Brazilian stock exchange and the largest global exchanges decided to pay the cost of entry. On the other side, mid-sized crypto-native operators left the Brazilian retail market: Coinext shut down its brokerage, stating that it did not reach the minimum regulatory capital required to file; NovaDAX and Digitra.com ended their retail activity; Lemon closed its Brazilian accounts; Bity confirmed it will not seek authorization; Bitso ended direct retail service.
That is the substance of the cycle. Regulatory capital did not shrink the market; it redistributed it from the specialized operator to the already supervised financial institution.
And the calendar did not stop. On November 3, monthly reporting of virtual asset transactions in the foreign exchange market, created by BCB Resolution No. 574, took effect. On November 6, the prohibition on regulated institutions dealing with unauthorized providers came into force — and, as discussed below, that date created a legal tension that, as of November 11, still had no formal clarification from the BCB.
In the United States, the move was different: instead of filtering operators, the agencies began to mark out territory. On October 5, the Commodity Futures Trading Commission (CFTC — the derivatives regulator) published an advance consultation on two regimes it intends to create. On October 20, the comment period closed on the proposal from the Securities and Exchange Commission (SEC — the securities regulator). The two pieces fit together — and, together, they leave a gap that only Congress can close.
In Hong Kong, the product the previous issue described as "has a name, but no date" went live: HSBC RedCoin launched on October 23 for more than 3.3 million PayMe users. And in Europe, the digital euro entered the final stage of legislative negotiation, where the dispute is no longer about whether to do it — it is about who sets the limit on how much each person can hold.
Brazil — The deadline did not empty the market: it changed the profile of who operates in it. An independent Cainvest survey, based on public sources, reached about 74 companies across requests, registrations and filings — including Binance, Coinbase, Bybit, OKX, Bitget, Kraken, Ripple, Mercado Bitcoin, Foxbit, Ripio, Itaú, Bradesco, Nubank, Inter, B3 and BTG Pactual. According to Bitnotícias, the BCB received about 852 documents on October 30 alone. None of these numbers amounts to a granted license, and the BCB's official list, released from November 6, showed 120 requests (119 under review and 1 rejected) and 24 institutions already enabled. Coinext, NovaDAX, Digitra.com, Lemon, Bity and Bitso, among others, left the retail market. On November 3, monthly reporting of virtual asset transactions in the FX market began (Resolution 574). On November 6, the prohibition in Art. 91 came into force — and the tension between that prohibition and the continuity that Art. 88 guarantees to those who filed on time still has no formal clarification from the BCB.
US — The CFTC opened a consultation; it did not publish a rule. And the spot market was left out. On October 5, the CFTC published a single Advance Notice of Proposed Rulemaking (ANPRM), consulting the market on two regimes it intends to create: Regulation Crypto Asset Transactions (Regulation CTX), for retail transactions involving leverage, margin or financing, and Regulation Crypto Asset Markets (Regulation CAM), a dedicated platform category. The document is preliminary, is not a final rule and imposes no new requirements; topics such as proof of reserves are open for comment, not established. The comment period runs until December 14, 2026. On October 20, the comment deadline expired for the SEC's consultation on Regulation Crypto Assets, with about 140 submissions according to Cointelegraph, on the eve of the deadline. The gap remains: simple spot trading stays outside federal jurisdiction and under state rules.
Europe — The digital euro is at the final table. The fight is over who sets the cap. The Council and the European Parliament concluded their positions and the bill entered the trilogue stage; the November 5 trilogue ended without agreement, and the goal is still to close the legislation by year-end, with the ambition of operating in 2029. Both sides agree on having online and offline versions, on exceptions to mandatory acceptance and on a design with strong privacy protection. They disagree on the essentials: Parliament wants the Commission to set the holding limit by delegated act; the Council wants an implementing decision of the Council itself, by reinforced qualified majority. They also disagree on legal entities, on the remuneration model for providers and on merchant fees.
Asia — RedCoin left the drawing board on October 23. HSBC launched its Hong Kong dollar stablecoin in the PayMe app, with more than 3.3 million users able to activate a wallet within the app itself and payments accepted at more than 100,000 merchants. The bank describes full backing by segregated high-quality, highly liquid assets, with one-to-one redemption by design. Three gaps remain: the product page does not say which blockchain RedCoin runs on; access is restricted to PayMe, with the bank's app planned for later; and the wholesale phase, for corporate and institutional clients, is still under exploration, with no date.
Latin America — Argentina keeps the banking ban. Colombia shelves its bill. In October, Juan Curutchet, superintendent of Financial and Exchange Entities at the Central Bank of the Argentine Republic (BCRA), stated that the authority will not promote the integration of cryptocurrencies into banking and payment channels for now. It is the authority's public position, not a new regulatory act: what is binding is the ban in force since 2022, which prevents financial institutions from carrying out or facilitating crypto asset transactions for their clients. In Colombia, Bill 510 of 2025, which would have created mandatory registration of providers and supervisory responsibilities, was shelved for running out of time in the House of Representatives. The region recorded US$ 593.8 billion in on-chain activity in the year to June 2026, up 9.8%, according to Chainalysis.
The previous issue closed with US regulators promising to act without a law. In October, they acted — and it is possible to see precisely what they can and cannot do on their own.
Let us start with the nature of the act, because it changes the weight of the news — and corrects the previous issue, which treated the document as a proposal. The CFTC did not publish two proposed rules. It published a single advance consultation document — an Advance Notice of Proposed Rulemaking (ANPRM) — that puts to the market two regimes the commission intends to build. The document itself states that it is not a final rule and imposes no new requirements: it seeks comments to help the agency develop a set of final rules. The comment period runs until December 14, 2026.
The first regime under consideration is Regulation Crypto Asset Transactions, abbreviated as Regulation CTX. It would define which retail crypto asset transactions fall under the commission's authority: those involving leverage, margin or financing. In those, the intermediary would be the futures commission merchant (FCM — a registered futures broker), which would bring into the transaction the anti-money laundering safeguards of the Bank Secrecy Act, as well as capital requirements and customer asset protection. The law already excludes from the CFTC's jurisdiction transactions with "actual delivery" within 28 days; the commission is consulting the market on how to apply that exception and, in a preliminary reading, understands that it only applies once delivery occurs.
The second is Regulation Crypto Asset Markets, or Regulation CAM, which would create a new platform category — crypto asset markets (CAMs) — designed as a narrower form of designated contract markets, the exchanges the CFTC already regulates. Among the points under discussion are a ban on listing products vulnerable to manipulation and the role that proof-of-reserves practices could play for customer assets held in omnibus accounts. To be clear: proof of reserves is among the topics open for comment and is not, at this stage, an established obligation.
The design under discussion is opt-in. Exchanges that chose to join the regime could offer margin and financing to retail customers under a single federal framework; those that did not would continue to operate under state spot market rules. Coinbase is cited as one of the companies positioned to benefit, since it already operates an FCM and a CFTC-regulated derivatives exchange.
CFTC Chairman Michael Selig summed up the agency's stance by saying it is doing its part to provide clear rules for crypto asset markets. And he signaled a specific concern for software developers: someone who merely writes code should not have to register as an introducing broker.
The agency is studying protections for developers who do not solicit orders or hold customer funds. For those who build infrastructure — and do not operate markets — this is the most relevant signal of the US quarter.
Here is the point that matters for decision-making. Simple spot trading — buying and selling a crypto asset at the market price, without leverage or margin — remains outside the CFTC's authority. Buying bitcoin or ether directly, or trading tokens such as XRP and Dogecoin, remains under state money transmission rules. The CFTC retains power to fight fraud and manipulation in these markets, but not to structure them.
Agency staff themselves say they do not yet know how large the spot market left outside the federal perimeter will be. And the reason for this gap is institutional, not technical: Congress never granted the CFTC jurisdiction over the crypto spot market, and the CLARITY Act — which would create the market structure framework — failed to advance in the Senate on September 15, in a procedural vote rejected 49 to 50.
The practical reading, and it is my reading: if this process ends as designed, the United States will have a reasonably complete federal regime for derivatives and leveraged retail transactions, and a state patchwork for everything else. For those operating in the country, this means the compliance question is no longer "what is the federal rule" but "which side of the line does my operation fall on".
On the securities side, the piece is Regulation Crypto Assets, published in the Federal Register on August 21, 2026 and identified as file S7-2026-27. The comment period closed on October 20. According to Cointelegraph, on October 19, the eve of the deadline, about 140 submissions had been received, six of them anonymous, including public support from industry groups.
It is worth describing what the proposal actually does, because the summary that circulated was inaccurate. The SEC is not declaring that tokens are no longer securities. It is creating a dedicated offering regime for what it calls "covered investment contracts" — investment contracts involving crypto assets. There are four core pieces.
The first is an exemption for early-stage companies: distribution for up to four years, raising up to US$ 5 million, subject to a notice filing and a transition report at the end. The second is a fundraising exemption modeled on Regulation A, in two tiers — up to US$ 20 million and up to US$ 75 million in each twelve-month period — filed on a new form, Form 1-CRYPTO, with financial statements and ongoing reporting at the upper tier.
The third is the safe harbor: the issuer may conclude that the investment contract has ended when it completes its essential managerial efforts, or when it permanently ceases those efforts, and the associated crypto asset is then no longer subject to that contract. This is where the substance of the proposal lies — and also its limit, because the safe harbor is expressly non-exclusive: private parties may still challenge that conclusion in court.
The fourth is state preemption: the definition of "qualified purchasers" removes state registration requirements, preserving the states' anti-fraud powers and certain notice and fee powers. Added to this are principles-based disclosure requirements — issuer commitments, offering terms, the token, governance, the network, cybersecurity and risks — and bad actor disqualification rules. In any scenario, issuers remain subject to federal anti-fraud and anti-manipulation provisions.
A note on method, for those who will use this in decision-making: the Federal Register web page is an unofficial prototype, and the legally binding text is the one published in official format. And none of this is a final rule — it is a proposal.
The digital euro project has moved past the stage of debating its merits and into the stage of negotiating the text. The Council of the European Union set its mandate in December 2025; the European Parliament approved its position on July 9, 2026; the trilogue between Parliament, Council and Commission began in July. The EU's political roadmap calls for the legislation to be closed by year-end, and the European Central Bank (ECB) is working with the ambition of being ready to issue from 2029, if the legislative timeline holds. Update: on November 5, according to Agence Europe, the trilogue ended without agreement, and the Irish presidency is seeking a political agreement on November 18.
Where there is agreement, it is real. Both sides foresee an online and an offline version. Both accepted that the online version should not be conditional on the absence of a private pan-European payment solution — a point that, in 2024 and 2025, was one of the main brakes. Both allow exceptions to mandatory acceptance depending on the type and size of the merchant, and both support a design with strong privacy protection, especially in the offline mode. And both guarantee the payer the choice between cash and the digital euro.
The first is the holding limit — and the dispute is not about the amount, it is about who has the power to set it. Both sides accept that there should be a cap. Parliament wants the European Commission to set it by delegated act, informed by an ECB recommendation, with Parliament and Council only able to object. The Council wants an implementing decision of the Council itself, adopted by reinforced qualified majority, based on an ECB recommendation agreed with the Commission. In practical terms: Parliament prefers a more technical and faster procedure; the Council wants to keep the decision under the control of the member states.
The second is the treatment of legal entities. Parliament wants to prohibit, in the text of the regulation itself, legal entities from holding digital euros. The Council would rather leave the details to the ECB, signaling the possibility of holding limits set at zero. The effect is similar; the route is different — and the route matters, because it determines how hard it will be to change the rule later.
The third is the remuneration model for payment service providers. Both sides propose uniform caps across the euro area, with a transition from an initial model to a cost-based model. Parliament would allow the transitional model to continue indefinitely, if a Commission report supports it. The Council sets a hard deadline: the transitional model must end within ten years at most.
The fourth is the fee charged to merchants. Parliament wants a cap per merchant. The Council wants national caps covering merchant fees and inter-provider fees, applicable only where they are well below the uniform caps. Fees for the offline mode remain unresolved, and the two sides still disagree on which personal data providers, the ECB and national central banks may process.
The reading from those who build infrastructure: none of these four points is cosmetic. The holding limit and the treatment of legal entities determine whether the digital euro will be a low-value retail instrument or a treasury asset. The remuneration model and the merchant fee determine whether banks will have an economic incentive to distribute the product. A digital euro that is legally mandatory and economically unattractive to those who distribute it would be the worst possible outcome.
Regardless of the negotiation, the operational side is moving forward. On July 14, the ECB selected 36 payment service providers for the pilot, which begins in the second half of 2027, and on September 15 it opened a call for e-commerce and mobile merchants. The version used in the pilot is a beta that resembles the digital euro but will not be legal tender.
And the caveat is worth repeating, because it survives every headline: issuance of the digital euro remains conditional on the approval of the legislation and on a subsequent decision by the ECB itself. The 2029 date is a stated ambition, not a firm commitment.
A note for the record, to correct a reading that circulated in the market. As of the close of this issue, the Bank of England had not published the final Code of Practice for systemic sterling-denominated stablecoins. What exists, since June 22, 2026, is a policy statement accompanied by a draft Code, whose public consultation closed on September 22. Finalization is still expected by the end of 2026, and the operation of regulated stablecoins in the UK in 2027 — still conditional on HM Treasury designating a stablecoin as systemic.
The terms of the draft remain those described in the previous issue: an initial issuance cap of £40 billion per product, replacing the per-holder limits previously considered; up to 70% of the backing in short-term UK government securities and the remainder in deposits at the central bank; and a ban on paying interest on balances, with rewards linked to payment use permitted.
On October 23, 2026, HSBC launched RedCoin, its Hong Kong dollar stablecoin, in the PayMe payments app. The bank said that more than 3.3 million PayMe users could activate a stablecoin wallet within the app in the following days, with the option to pay at more than 100,000 merchants in the network. Users can send RedCoin instantly to other people.
On the backing, the bank states that the coin is fully backed at all times by segregated high-quality, highly liquid assets, and that it was designed to be redeemable one-to-one in Hong Kong dollars. It is worth noting that this is the issuer's own description, not an independent verification — and that the public material does not detail the composition of the reserve.
The first: the product page does not say which blockchain RedCoin runs on. For a retail payment token distributed within an app, this may seem like a technical detail. It is not. Without knowing the network, there is no way to know whether the asset can be transferred outside the issuer's environment, or under what conditions — and that is exactly the question that separates a stablecoin from a tokenized balance.
The second: access is restricted to PayMe, with HSBC's mobile banking app in Hong Kong planned for later. The public material does not clarify whether transfers to external wallets are possible. Combined with the first gap, what emerges is a product that works, today, as an internal rail of an ecosystem — a large one, with 3.3 million users and 100,000 merchants, but internal.
The third: the wholesale phase, aimed at corporate and institutional clients, is still described as exploration with designated partners, with no date. The bank also plans a tokenized funds wallet in the app later this year.
None of this diminishes the achievement. In just over six months, HSBC went from a license granted by the Hong Kong Monetary Authority (HKMA) on April 10 to a live payment product, in a jurisdiction with anti-money laundering requirements among the strictest in the world. It is worth recalling the design of those requirements, to the extent the sources support: licensed issuers must maintain identification and verification controls on the wallets customers use for issuance and redemption, with risk-based monitoring at both points, and apply the rule requiring originator and beneficiary information to be passed on in covered transfers, with a threshold of HK$ 8,000, about US$ 1,000.
The reading: Hong Kong is proving that it is possible to launch a regulated bank stablecoin within a short time, provided the product is born inside a controlled perimeter. The open question — and it applies to any bank considering the same path — is whether the next step, opening the token beyond its own app, is a planned evolution or a wall.
This is the cycle in which Brazilian regulation produced visible consequences. It is worth separating what happened into four layers: who came in, who left, what is still to come and the legal tension no one has resolved.
In the final weeks before October 30, the list of requests grew quickly. On October 29, Coinbase, Ripple and Inter confirmed their filings. Coinbase filed under the virtual asset service provider regime, with plans that also cover foreign exchange, payments and electronic money issuance — and each of these activities requires its own approval. Ripple submitted documentation on October 28, without disclosing a case number or the type of license requested. Inter filed a request related to Inter Digital Assets, also without detailing the type, planned capital or services included. Itaú reported intermediation and custody activities under the procedure applicable to already authorized financial institutions.
Before them, there were already confirmed requests from Binance, Mercado Bitcoin, Ripio, Bybit and OKX. In mid-October, OKX filed on October 16, seeking to operate as a virtual asset broker and also authorization for the FX market; Brasil Bitcoin filed on October 15; and UnblockPay announced its request on October 19, seeking brokerage and FX.
The numbers call for care, and it is worth following how they moved. On October 19, the most detailed survey counted 11 known requests — OKX, Brasil Bitcoin, UnblockPay, Crown, Transfero, Mazzera, PFPay, Masterpay, W Brasil Comércio, Onda Finance and Wynx Exchange. On October 29, the day before the deadline, the total number of companies appearing in requests, registrations or filings reached 25. After the deadline, the independent Cainvest survey reached about 74 companies, also including Bitget, Kraken, Foxbit, Liqi, Bradesco, Nubank, B3 and BTG Pactual.
The curve from 11 to 25 and then to 74 in about two weeks says something about market behavior: most filed in the final window. According to Bitnotícias, the BCB received about 852 documents on October 30 alone, and approximately 4,311 over the whole month — a number of documents, not of distinct requests, some of them identified only by the name of the lawyer or law firm, without attribution to a company.
Four caveats worth keeping in mind, because this is the point in the cycle where the number became a headline. First: the Cainvest survey is an independent compilation from public sources — company announcements, case numbers and the Federal Official Gazette (DOU) — not an official list. Second: the BCB's official list was released from November 6 and became the reference. It is on the bank's authorization processes page and shows 24 already supervised institutions enabled to provide virtual asset services (8 in custody and intermediation, 16 in intermediation only, including Itaú, Bradesco and BTG Pactual) and 120 requests from dedicated providers: 119 under review and 1 rejected, of which 46 are brokers, 1 is a custodian and 73 are intermediaries. The sum, 144, is of records, not of distinct companies. Coinbase, OKX, Bybit, Mercado Bitcoin, Ripio, Ripple and Foxbit are listed as under review, and Kraken appears as Payward Brasil; Binance and Bitget do not appear by name. Third: being in the Cainvest survey does not prove a license, an authorization or a validated request — several records rely only on the company's own announcement. Fourth: filing is not authorization, and the public database shows cases at different stages — under review, scheduled, awaiting receipt, awaiting the applicant's response.
And there has already been a rejection. The request from Higherway Tech Soluções, case 304022, was rejected — a decision dated August 25, 2026, published in the Federal Official Gazette on September 28, according to the October 10 survey. It is the first known rejection under the regime, and a reminder that the queue is not a formality.
It is also worth noting who does not appear. Among the relevant names with no filing found are KuCoin, BIPA, Tether and Gate.io. Circle and Paxos have legal entities in Brazil, which does not prove a request. For those structuring counterparties, this list is as operational as the list of those who filed.
The list of exits is the part of the story the market tends to underestimate, because it shows the real cost of regulatory capital.
The most explicit case is Coinext, which shut down its brokerage, stating in its own announcement that it did not reach the minimum regulatory capital required to file. Trading ended on October 15, crypto withdrawal requests closed on October 20 and remaining assets began to be converted into reais from October 26. Digitra.com stated that it would not file for authorization and ended retail trading and custody, referring customers to Foxbit. NovaDAX ended trading and also referred customers to Foxbit, with custody ending on October 31. Bity confirmed it will not file as a provider, with migration starting in November and conversion into reais on November 27.
Lemon announced its exit from Brazil citing the new rules: its card was discontinued on September 30 and its Brazilian accounts on October 16. Bitso ended direct retail service in the country on October 30, migrating to Mercado Bitcoin — a move that does not amount to a full exit. After the deadline, other exits joined the list: Uphold, with redemptions until November 30; Oobit, with Pix and card until November 6 and accounts closed on November 30; Revolut's crypto services until November 25; as well as Bitnuvem and Crypto Use. CoinEx announced a global shutdown, with withdrawals until December 22.
There were also reductions that are not exits: Méliuz stopped bitcoin purchases, Crypto.com closed its reais account on October 25 while keeping other services, and Ripio stopped holding balances in reais from October 30, migrating to a wBRL structure.
The dates and reasons above come from the companies' own announcements, reported in specialized coverage, and not from regulatory acts. For anyone relying on one of these platforms, the company's official announcement is the source to check.
The final deadline for those who did not file comes from Article 88 itself: a provider that did not file must wind down its activities within 30 days, which leads to November 29, with guidance to customers on withdrawing funds. Note that, for these companies, banking access ended earlier — on November 6 — so the practical window to move funds is shorter than the formal one.
Three milestones shape the calendar; the first two have already passed.
On November 3, 2026, monthly reporting of virtual asset transactions in the FX market took effect. The obligation was created by BCB Resolution No. 574, of June 18, 2026, which amended Article 82-A of BCB Resolution No. 277, which in turn refers to Annex II-A. The reporting covers transactions with crypto assets, stablecoins and other virtual assets referenced in fiat currency. The original design called for a start in May 2026; the rule moved the obligation to transactions carried out from November 3, with data due by the fifth day of the following month, in the form the central bank defines. In practical terms: the first data submission is due in early December, and it covers whatever has been traded since November 3.
On November 6 — a Friday, three days later — the prohibition in Article 91 of BCB Resolution No. 520 came into force, as worded by BCB Resolution No. 589, of September 23, 2026. From that date, regulated institutions are barred from carrying out or enabling transactions in the virtual asset market with providers that are not authorized to operate in the country. This is the date that shifts the risk: on October 30, what was at stake was the provider's own status; on November 6, what came to be at stake was the status of its counterparties.
This is the most relevant point in this issue for anyone operating in Brazil, and it did not appear in the coverage of the deadline.
BCB Resolution No. 520 has, in paragraph 6 of its Article 88, a transition rule: a provider that filed its request within the deadline may keep operating until the process is concluded, and may not take on another type of activity during that period. In other words, those who met October 30 have guaranteed continuity — and Resolution 520 sets no deadline for the BCB to decide. That limit comes from BCB Resolution No. 594, of September 30, 2026: up to 1,080 days to authorize providers already in operation and up to 720 days for those not yet operating, for requests filed after it took effect.
The problem lies in the other article. In its original wording, with effects scheduled for October 30, Article 91 barred regulated institutions from dealing with providers "not authorized or in the process of authorization". Resolution 589 did two things at once: it moved the effective date to November 6 and deleted the phrase "or in the process of authorization". The text that took effect on November 6 bars transactions with providers "that are not authorized to operate in the country".
The deletion can be read in two opposite ways, and that is where the tension lies. In one reading, removing the reference to the authorization process means that an applicant under review is no longer expressly barred — and would therefore be allowed. In the other, Article 91 now refers only to authorized providers, and an applicant under review is not authorized — and would therefore be barred. Both readings are defensible from the text, and the practical outcome is opposite: on one side, a company that filed on time keeps banking access while the process runs; on the other, it keeps the right to operate under Article 88 and loses banking access under Article 91 — a right with no means of exercising it.
As of November 11, we had found no formal statement from the BCB reconciling the two provisions. The practical recommendation circulating among the sector's legal advisers is direct and worth repeating: those who filed should ask their bank, in writing, how the account will be treated given their status, whether there will be restrictions or closure and from when — and have a contingency plan ready, because a restrictive answer may come late.
In my reading, this is a drafting gap with material consequences, not an academic question. It affects precisely the companies that did the right thing: they filed on time and are awaiting a decision. Guidance from the regulator would solve the problem in a single paragraph.
On January 1, 2027, the precautionary hold of up to 24 hours under BCB Resolution No. 584 takes effect, for virtual asset transfers to providers abroad or to self-custodied wallets above the equivalent of US$ 10,000, in a single transaction or in the customer's daily total, with the possibility of early release upon a documented risk analysis.
It is worth recalling that the October 1 package is already having an effect: Resolution 561, which bars the use of virtual assets in settling the foreign leg between the regulated electronic FX provider and its counterparty abroad; Resolution 575, which expanded the range of legal entities that can hold foreign currency accounts in the country; and Resolution 588, revoked and replaced by BCB Resolution No. 591, of September 30, 2026, which created mandatory reporting to the Financial Activities Control Council (COAF) for virtual asset transfers involving self-custodied wallets from US$ 10,000, with the first report, covering October to December transactions, due on the first business day of January 2027.
Official data help explain why the regulator sped up. According to a survey released by the Federal Revenue Service (Receita Federal) on July 23, 2026, from August 2019 to December 2025, R$ 1.58 trillion in crypto asset transactions were declared in Brazil, of which R$ 1.13 trillion — 71.7% — were in stablecoins, with a share in the 76% to 80% range in 2024 and 2025. Among declared stablecoins, USDT accounts for 88.7% of the volume, USDC for 7.1% and BRZ for 3.4%.
Those who build infrastructure for regulated markets learn early that the hard part is never the technology — it is who is accountable for each link. What Brazil did in this cycle was answer that question literally: from November 6, every regulated institution needs to know whether its counterparty is authorized. This is costly and redraws the list of available partners. It is also, in my reading, the only design in which a real-denominated stablecoin may eventually compete with a dollar token issued abroad — because it shifts the basis of comparison from price and speed to accountability and legal address.
An honest note on the reading of this cycle: the conclusion that "the market shrank" is not supported by the numbers. The official list, with 120 requests and 24 enabled institutions, shows more players seeking to enter the supervised perimeter — not fewer. What shrank was a specific category of participant: the mid-sized crypto-native exchange, without regulatory capital for entry. Calling this consolidation is defensible; calling it a reduction of the market is not.
For those making decisions now, the three operational questions of the month are not about technology. Whether the data flow required since November 3 is in place. Whether the list of counterparties has been checked against the BCB's official list. And, for those who filed and are awaiting a decision, whether their bank has already answered in writing how it will treat the account since November 6.
While Brazil was filtering operators, two neighbors offered the most useful contrast of the cycle: one country where the regulator decided not to move, and another where the legislature could not decide.
In Argentina, in October 2026, Juan Curutchet, superintendent of Financial and Exchange Entities at the Central Bank of the Argentine Republic (BCRA), stated publicly that the authority will not promote the integration of cryptocurrencies into banking and payment channels for now, linking the position to the country's economic conditions and indicating, according to the Argentine newspaper El Cronista, that the topic would only return to the agenda in a possible second term for Javier Milei.
Precision matters: this is not a new regulatory act. It is the public expression of the authority's current position, with no timeline or gradual authorization announced. What is binding is the existing ban, which prevents financial institutions from carrying out or facilitating crypto asset transactions for their clients and has been in force since 2022 — and which therefore remains unrevised in a country that, as we noted in the previous issue, has 94% of its peso-denominated crypto trading volume going to stablecoins. A future revision is not legally blocked by the statement; it is simply not on the stated horizon.
The contrast is noteworthy. According to a16z crypto, Argentina has the largest share of stablecoins in peso crypto volume among the markets analyzed and, at the same time, keeps its banks out of the market. The predictable effect is that demand — which exists and is documented — will be met by non-bank providers and offshore infrastructure. It is the opposite configuration to Brazil's: in Brazil, the regulator is bringing the activity into the supervised perimeter; in Argentina, it is keeping the banking perimeter closed and leaving the activity outside it.
In Colombia, Bill 510 of 2025, introduced in the House of Representatives in February 2025, was shelved in that chamber for running out of time. The bill provided for mandatory registration of virtual asset service providers, a clear definition of supervisory responsibilities and investor protections. Coverage of the episode reported that it would be the third consecutive year in which a comprehensive proposal failed; since we did not find individual references to the bills of previous years, we prefer to record only what is documented — the shelving of this bill.
The region keeps growing. On-chain activity in Latin America totaled US$ 593.8 billion in the year to June 2026, up 9.8% from the previous period, according to Chainalysis. For reference on regional positioning, in the Chainalysis 2025 Global Crypto Adoption Index — sixth edition, published on September 2, 2025 — three countries in the region rank in the top twenty: Brazil 5th, Venezuela 18th and Argentina 20th.
The regional reading: Latin America today has three models operating simultaneously. The Brazilian one, a supervised perimeter with a high cost of entry and consolidation as a consequence. The Argentine one, high demand and a barred banking system, with the activity happening outside. And the Colombian one, no legal framework due to legislative failure, with the activity under general rules. None of the three is an accident; each is a choice with measurable consequences.
The period between October 7 and November 11, 2026 marked the shift from declared regulation to regulation with effect.
In Brazil, the rule redistributed the market: large banks, the stock exchange and the largest global exchanges paid the cost of entry, mid-sized native operators left, and more companies began seeking the supervised perimeter, not fewer — only with a different profile. In the United States, the agencies began to mark out territory, still at the consultation stage, and in doing so made visible the gap that none of them can fill on its own. In Hong Kong, a bank showed that it is possible to launch within months, provided the product is born inside a controlled perimeter, with interoperability questions postponed for later. In Europe, the discussion reached the point where the economic design of the instrument — holding limit, legal entities, remuneration of distributors — will be decided at a legislative negotiating table, not in a lab.
There is a pattern in this, and it is worth naming. In 2026, countries stopped asking whether digital currencies will exist and started deciding who can operate them. The answer has been, in almost every case, the same: institutions that bear the cost of being identifiable, auditable and accountable. It is an expensive filter — and, in my reading, it is the filter that makes the next stage possible, because financial infrastructure only scales when it is clear who is accountable when something goes wrong.
For the next cycle, four concrete markers: the BCB's official list of requests (released by the bank from November 6 and updated periodically), which now replaces independent counts; the first submission of Brazil's FX virtual asset transaction reporting, in early December; the close of the comment period for the CFTC consultation, on December 14; and whether or not the digital euro legislation is closed by year-end. There is also a Brazilian open issue worth following: whether the BCB will clarify how Article 91 applies to those who filed on time and are awaiting a decision.
— André Carneiro, CEO, BBChain
Greenberg Traurig — CFTC seeks comments on proposed framework for retail crypto asset trading and markets (um único ANPRM, de caráter preliminar; prazo de comentários até 14 dez 2026), out 2026 https://www.gtlaw.com/en/insights/2026/10/cftc-seeks-comments-on-proposed-framework-for-retail-crypto-asset-trading-and-markets
CoinDesk — U.S. CFTC joins SEC in proposing crypto regulations, though spot-market gap lingers, 5 out 2026 https://www.coindesk.com/policy/2026/10/05/u-s-cftc-joins-sec-in-proposing-crypto-regulations-though-spot-market-gap-lingers
Forbes — CFTC moves to set rules for leveraged crypto trading in the U.S., 5 out 2026 https://www.forbes.com/sites/ninabambysheva/2026/10/05/cftc-moves-to-set-rules-for-leveraged-crypto-trading-in-the-us/
Federal Register — Regulation Crypto Assets, 91 FR 54510, proposta da SEC (File No. S7-2026-27); prazo de comentários encerrado em 20 out 2026, 21 ago 2026 https://www.federalregister.gov/documents/2026/08/21/2026-17183/regulation-crypto-assets
The Legal 500 — SEC seeks comments on proposed crypto asset offering rules by October 20, 2026 (isenções, safe harbor e preempção estadual), 12 out 2026 https://www.legal500.com/intelligence/united-states/international-law/sec-seeks-comments-on-proposed-crypto-asset-offering-rules-by-october-20-2026
Cointelegraph — SEC to Move Forward With Proposed Crypto Rules After Failed CLARITY Vote (cerca de 140 comentários, seis anônimos, às vésperas do encerramento do prazo), 19 out 2026 (atualizada em 23 out) https://cointelegraph.com/news/public-comments-us-sec-proposed-crypto-rules
Orrick — The CLARITY Act stalls in the Senate: what's next for digital asset regulation, 2 out 2026 https://www.orrick.com/en/Insights/2026/10/The-CLARITY-Act-Stalls-in-the-Senate-Whats-Next-for-Digital-Asset-Regulation
Freshfields — Europe's digital euro heads to last stage of negotiations: what Council and Parliament agree on, and where they still clash, 2026 https://www.freshfields.com/en/our-thinking/blogs/technology-quotient/europes-digital-euro-heads-to-last-stage-of-negotiations-what-council-and-parl-102nbx6
BCE — ECB selects 36 payment service providers to join digital euro pilot, 14 jul 2026 https://www.ecb.europa.eu/press/pr/date/2026/html/ecb.pr260714~8cd07d9d45.en.html
CoinDesk — European Central Bank calls for merchants to participate in digital euro pilot, 15 set 2026 https://www.coindesk.com/policy/2026/09/15/european-central-bank-calls-for-merchants-to-participate-in-digital-euro-pilot
Agence Europe — Negotiations intensify between European Parliament and EU Council on digital euro (trílogo de 5 nov sem acordo; presidência irlandesa busca acordo político em 18 nov), 6 nov 2026 https://agenceurope.eu/en/bulletin/article/13977/18/negotiations-intensify-between-european-parliament-and-eu-council-on-digital-euro
The Paypers — Bank of England publishes stablecoin rules for systemic issuers (declaração de política e rascunho de Código de Prática; finalização prevista para o fim de 2026) https://thepaypers.com/regulations/news/bank-of-england-publishes-stablecoin-rules-for-systemic-issuers
Addleshaw Goddard — Sterling-denominated systemic stablecoins: the Bank of England's policy statement and Draft Code of Practice, 2026 https://www.addleshawgoddard.com/en/insights/insights-briefings/2026/financial-regulation/sterling-denominated-systemic-stablecoins-bank-englands-policy-statement-draft-code-practice/
Disruption Banking — HSBC RedCoin goes live on PayMe for 3.3 million Hong Kong users, 23 out 2026 https://www.disruptionbanking.com/2026/10/23/hsbc-redcoin-goes-live-on-payme-for-3-3-million-hong-kong-users/
HSBC — HSBC names stablecoin 'HSBC RedCoin', 30 set 2026 https://www.about.hsbc.com.hk/news-and-media/hsbc-names-stablecoin-hsbc-redcoin
CoinDesk — Hong Kong awards first stablecoin licenses (identificação de carteiras e travel rule de HK$ 8 mil), 10 abr 2026 https://www.coindesk.com/policy/2026/03/24/hong-kong-awards-first-stablecoin-licenses-to-hsbc-standard-chartered-led-group
BitNotícias — Licença cripto do Banco Central: qual exchange pediu, quem vai pedir e quem está saindo do Brasil (base pública do BCB; saídas confirmadas), 10 out 2026 https://bitnoticias.com.br/noticias/licenca-cripto-do-banco-central-qual-exchange-pediu-quem-vai-pedir-e-quem-esta-saindo-do-brasil
BPMoney — OKX, Brasil Bitcoin e UnblockPay pedem licença cripto ao BC a dias do prazo (11 pedidos conhecidos; prazo de 29 nov para encerrar serviços), 19 out 2026 https://bpmoney.com.br/mercado/cripto/okx-brasil-bitcoin-unblockpay-pedem-licenca-cripto-banco-central/
Webitcoin — Coinbase, Ripple e Inter pedem licença ao Banco Central (Itaú, Binance, Mercado Bitcoin, Ripio, Bybit e OKX; 25 empresas em pedidos, registros ou comunicações), 29 out 2026 https://webitcoin.com.br/coinbase-ripple-e-inter-pedem-licenca-ao-banco-central/
BitNotícias — O prazo do Banco Central acabou e agora? Quem pediu licença cripto, quem ficou de fora e quem foi embora do Brasil (levantamento Cainvest: 74–75 empresas; ~852 documentos em 30 out e ~4.311 em outubro), out/nov 2026 https://bitnoticias.com.br/noticias/o-prazo-do-banco-central-acabou-e-agora-quem-pediu-licenca-cripto/
Transfero — Prazo PSAV 30/10/2026: o que acontece com quem não pedir (art. 88 da Resolução BCB nº 520: continuidade do requerente tempestivo até a decisão; 30 dias para encerrar) https://transfero.com/pt/artigos/prazo-autorizacao-psav-30-outubro
Blue Consult — Faltam 6 dias para 06/11: os bancos e a mesa P2P (art. 91 na redação da Resolução BCB nº 589; supressão da expressão "ou em processo de autorização") https://blueconsult.com.br/faltam-6-dias-06-11-bancos-mesa-p2p/
Cointelegraph Brasil — Banco Central muda regra e adia reporte de operações com cripto no câmbio (Resolução BCB nº 574; operações a partir de 3 nov 2026), 19 jun 2026 https://cointelegraph.com.br/news/brazilian-central-bank-stablecoins-law
LegisWeb — Resolução BCB nº 589, de 23 set 2026 (alteração do art. 91 da Resolução BCB nº 520, com efeitos a partir de 6 nov 2026) https://www.legisweb.com.br/legislacao/?id=502015
Conjur — Resolução do BC passa a exigir comunicação ao Coaf em transferências de cripto autocustodiada (Resoluções BCB nº 588 e 589), 29 set 2026 https://conjur.com.br/2026-set-29/resolucao-do-bc-passa-a-exigir-comunicacao-ao-coaf-em-transferencias-de-cripto-autocustodiada/
Cepeda Law — SPSAVs: a contagem regressiva para 30 de outubro de 2026 https://cepeda.law/spsavs-a-contagem-regressiva-para-30-de-outubro-de-2026/
LegisWeb — Resolução BCB nº 561, de 30 abr 2026 (art. 50; vigência 1º out 2026) https://www.legisweb.com.br/legislacao/?id=495246
Receita Federal — Stablecoins já respondem por cerca de 80% do volume declarado de criptoativos no Brasil, 23 jul 2026 https://www.gov.br/receitafederal/pt-br/assuntos/noticias/2026/julho/stablecoins-ja-respondem-por-cerca-de-80-do-volume-declarado-de-criptoativos-no-brasil
Banco Central do Brasil — Processos de autorização: pedidos de SPSAV (120 registros; 119 em exame, 1 indeferido) e instituições habilitadas a prestar serviços de ativos virtuais (24), consultado em 11 nov 2026 https://www.bcb.gov.br/estabilidadefinanceira/autorizabc?modalAberto=spsavs-pedido-fase
Banco Central do Brasil — Resolução BCB nº 520, de 10 nov 2025 (art. 88, §§ 6º e 7º; art. 91 na redação da Resolução BCB nº 589), versão vigente atualizada em 30 set 2026 https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?tipo=Resolu%C3%A7%C3%A3o%20BCB&numero=520
Banco Central do Brasil — Resolução BCB nº 574, de 18 jun 2026 (art. 82-A da Resolução BCB nº 277) https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?tipo=Resolu%C3%A7%C3%A3o%20BCB&numero=574
Banco Central do Brasil — Resolução BCB nº 591, de 30 set 2026 (altera a Circular nº 3.978 e revoga a Resolução BCB nº 588) https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?tipo=Resolu%C3%A7%C3%A3o%20BCB&numero=591
Banco Central do Brasil — Resolução BCB nº 594, de 30 set 2026 (prazos máximos de decisão; autorização de prestadoras de serviços de ativos virtuais: 1.080 e 720 dias) https://www.bcb.gov.br/estabilidadefinanceira/exibenormativo?tipo=Resolu%C3%A7%C3%A3o%20BCB&numero=594
Latin Times — What Brazil's crypto deadline, Colombia's shelved bill and Argentina's banking ban reveal about Latin America's $593 billion digital economy, 28 out 2026 https://www.latintimes.com/latin-america-crypto-regulation-brazil-vasp-deadline-600659
DiarioBitcoin — Argentina congela por dos años la integración de criptomonedas en bancos y pagos (declaração de Juan Curutchet, BCRA), 11 out 2026 https://www.diariobitcoin.com/argentina/argentina-congela-por-dos-anos-la-integracion-de-criptomonedas-en-bancos-y-pagos/
El Cronista — El BCRA postergó el fin del cepo, pero adelantó que será en el segundo mandato de Milei (declaração de Juan Curutchet, superintendente de Entidades Financieras y Cambiarias do BCRA), 7 out 2026 https://www.cronista.com/finanzas-mercados/cepo-al-dolar-y-cripto-el-bcra-adelanto-que-los-levantara-en-un-eventual-segundo-mandato-de-milei/
Chainalysis — The 2025 Global Crypto Adoption Index (sexta edição, publicada em 2 set 2025) https://www.chainalysis.com/blog/2025-global-crypto-adoption-index/
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