IPS . finance

Our regulatory approach

Operating within the Brazilian regulatory framework.

IPS's regulatory architecture is built around three principles: we operate through licensed Brazilian câmbio partnerships, providing the customer experience, orchestration, and operational layer above regulated settlement infrastructure; customer balances are held in fiat currency throughout, with the platform's only use of distributed-ledger technology being internal, tamper-evident audit logging; and our architecture is structurally consistent with the regulatory framework that governs Brazilian payments. This page describes the framework in detail.

Operating through chartered câmbio partnerships.

IPS operates as a customer-facing layer over partnerships with chartered Brazilian câmbio institutions. The partner câmbio bank holds Bacen authorisation for foreign exchange operations and performs the regulated FX leg of every cross-border transaction that flows through our platform. These operations fall under the Brazilian electronic-FX framework — Resolução BCB 277/2022, as amended by Resolução BCB 561/2026 — which sets the information, reporting, and KYC/KYP requirements the partner observes. IPS provides the customer-facing experience and the orchestration infrastructure; the partner câmbio bank performs the regulated activity. This framework operates under CMN Resolução 4,935 of 2021, which establishes the correspondente cambial relationship between non-bank operators and chartered câmbio institutions. The relationship is the same model used by other Brazilian financial entities — including major fintechs and established financial services companies — to operate cross-border flows through partnerships with the institutions that hold the underlying authorisations. IPS does not directly hold a câmbio licence and does not perform the regulated FX leg. The partner bank performs it; IPS supports the customer-facing layer that connects customers to the regulated FX operation. This is a structural choice. The framework allows IPS to focus on the engineering and customer experience while the partner bank provides the regulatory infrastructure that already exists within their charter.

Virtual assets and the PSAV framework.

Customer-facing balances are held in fiat currency — US Dollar, Euro, British Pound, Australian Dollar, and Brazilian Real. The product involves no digital assets at any point in the customer journey: IPS does not issue, custody, or transfer virtual assets on behalf of customers. The distributed-ledger component of the IPS architecture — specifically Hedera Consensus Service, used solely for tamper-evident audit logging (Wolf Proof) — operates as internal infrastructure only; Hedera's role is the anchoring of audit records for events completed through the regulated settlement rails, and customer balances are never represented on Hedera. On this basis, IPS does not operate as a Prestador de Serviços de Ativos Virtuais (PSAV) — a conclusion supported by IPS's formal legal opinion.

Standard IOF treatment through the câmbio partner.

Standard IOF (Imposto sobre Operações Financeiras) applies to all foreign exchange operations executed through the partner câmbio institution. The retail rate of 0.38% applies to the customer-facing flows IPS supports. This is the same IOF treatment that applies to traditional retail foreign exchange operations conducted through any chartered câmbio bank in Brazil. IPS does not engage in operations that would trigger the higher 4% rate applicable to outbound capital flows. The customer flows IPS supports — foreign visitors funding Real for Brazilian spending, Brazilian residents and businesses receiving international payments — fall structurally within the retail framework rather than within the capital-outflow framework. The customer flow patterns do not resemble capital flight; they are legitimate commercial cross-border activity that the Brazilian regulatory framework explicitly supports. Income tax, social contributions, and other tax obligations applicable to IPS's operations are handled through standard accounting and tax compliance processes. The company's tax posture is straightforward — no special structures, no offshore arrangements, no tax-optimisation architectures that would create regulatory concern.

LGPD compliance integral to operations.

Compliance with Lei Geral de Proteção de Dados (LGPD, Lei 13.709 of 2018) is integral to how IPS operates. A Data Protection Officer is designated and reachable at dpo@ips.finance. The company's privacy policy is publicly accessible and describes how personal data is collected, processed, and protected. Data processing follows the principles of minimisation, purpose limitation, and security required by LGPD. For customers in the European Union — Journey 1 funding via SEPA and Journey 2 payers — personal data is also handled in accordance with the GDPR, including a lawful basis for processing and safeguards for international data transfers. Customer rights under LGPD — access, correction, deletion, portability, objection — are supported through the DPO contact channel. Requests are responded to within the statutory timeframes. For a fuller description of the data protection programme, see Security and privacy in this section.

Built for the regulatory environment that is emerging.

Brazilian regulators have signalled a clear direction for the payments sector over the past several years. The framework prioritises consumer protection, financial system stability, AML and CFT integrity, tax base preservation, and the supervised conduct of regulated activities. The framework around virtual assets under Lei 14.478, the continued evolution of Pix as the dominant Brazilian payment rail, and the development of Drex as the Bacen-controlled digital settlement infrastructure all reflect aspects of this direction. IPS's architecture is structurally aligned with this direction. We settle through regulated FX rails. We pay standard IOF rather than operating in tax-arbitrage gray zones. We integrate with Pix as the dominant Brazilian payment rail. We complement the partner bank's existing supervisory framework rather than seeking to operate outside it. As the regulatory environment continues to evolve, our architecture is well-positioned to evolve with it rather than against it.

Detailed documentation

This page describes IPS's regulatory approach at a level appropriate for public institutional reading. Detailed regulatory documentation — including the Compliance Memorandum with legal counsel parecer, specific partner-bank documentation, and operational compliance policies — is available to institutional partners through the institutional access process.