AML and CFT

Our anti-money-laundering and counter-terrorist-financing programme.

Anti-money-laundering and counter-terrorist-financing obligations are core to operating in the Brazilian payments space. IPS maintains an AML and CFT programme appropriate to a fintech operating through chartered câmbio partnerships. The programme implements customer due diligence, transaction monitoring, suspicious activity reporting through the COAF framework, and ongoing risk management — coordinated with the partner câmbio bank's supervisory obligations.

The structure of our programme.

IPS's AML and CFT programme operates across four functional areas: customer due diligence at onboarding and on an ongoing basis; real-time transaction monitoring through the Wolf Watch infrastructure module; case management and disposition workflows for alerts generated by monitoring; and reporting obligations including those that flow to COAF (Conselho de Controle de Atividades Financeiras) and through the partner câmbio bank to Bacen. The programme is documented in internal policies and procedures that are reviewed and updated as regulatory expectations evolve. Programme effectiveness is reviewed periodically. Training is provided to relevant staff. Records are maintained in line with the retention requirements that apply to financial services.

KYC and KYB at onboarding and beyond.

Customer due diligence begins at onboarding and continues throughout the customer relationship. Individual customer onboarding includes identity verification through validated identity documents, biometric confirmation where appropriate, sanctions list screening, politically exposed person screening, and risk-based classification of the customer profile. Business customer onboarding adds know-your-business procedures: corporate document collection (contrato social, ata de eleição da diretoria, procuração where applicable), beneficial ownership identification and verification through Brazilian corporate registries, business activity classification through CNAE codes, sanctions and PEP screening of beneficial owners and authorised representatives. The depth of KYB is scaled to the customer risk profile and the nature of the business activity. Ongoing due diligence continues after onboarding. Customer profiles are re-verified periodically. Sanctions screening runs continuously against updated watch lists. Business customer profiles are reviewed when corporate changes occur — changes in beneficial ownership, in authorised representatives, in CNAE classification. The customer record is treated as a living state that the programme maintains, not as a one-time onboarding artefact.

Continuous monitoring through Wolf Watch.

Every transaction that flows through the IPS platform is monitored in real time by the Wolf Watch infrastructure module. The monitoring evaluates transaction patterns against detection rules covering money laundering indicators, terrorist financing indicators, structuring patterns, layering patterns, sanctions screening, and the broader set of patterns that the regulatory framework requires monitoring against. Alerts generated by monitoring flow into case management for compliance review. Compliance staff investigate alerts in context, gather additional information where required, and reach disposition decisions: closure as false positive, escalation for additional review, confirmation as suspicious activity requiring SAR filing, or other appropriate disposition. Every alert and its disposition is documented; the case management trail supports regulatory review and internal audit. Specific detection rules and thresholds are not published publicly. Publishing these details would assist bad actors in evading detection. Regulators and partner banks with legitimate need to understand the detection framework receive that information through institutional channels.

COAF reporting and the partner-bank framework.

Brazilian AML and CFT reporting obligations flow through two channels relevant to IPS's operations. Suspicious activity reporting goes to COAF under the framework established by Lei 9.613 of 1998 and the implementing regulations. Operational reporting tied to câmbio operations flows through the partner câmbio bank's Bacen supervisory submissions under the framework that applies to câmbio institutions. IPS's AML and CFT programme is structured to support both channels. Suspicious activity reports prepared by IPS's compliance function are filed with COAF through the formal reporting channel. Information that supports the partner bank's Bacen submissions flows through to the partner under the operational arrangements that govern the correspondente cambial relationship. The coordination between IPS's programme and the partner bank's programme is intentional. The partner bank already operates under Bacen supervision and has the supervisory relationship that IPS does not directly hold. Rather than duplicating or competing with the partner bank's monitoring, IPS's programme complements it — monitoring at the customer and platform level where the partner-side monitoring would not see, and providing information to the partner that supports their supervisory obligations.

Complementary monitoring across the operational chain.

The relationship with the partner câmbio bank is the structural foundation of IPS's operations. The AML and CFT programme reflects this. Information flows between IPS and the partner bank under appropriate arrangements — anonymised customer risk indicators, transaction-level monitoring results, alerts and dispositions, regulatory submissions — to support each party's compliance obligations without creating duplicative friction. This coordination is operationally important. A partner bank evaluating IPS as a correspondente partner wants to see an AML and CFT programme that complements rather than complicates the partner's own supervisory obligations. Our programme is designed for that complementarity.