Yes, accountants in Brazil may be obligated to comply with anti-money-laundering (AML) rules and to report to COAF. CFC Resolution No. 1,530/2017, supported by Law 9,613/1998, places accounting professionals and firms among the obligated sectors. This guide explains what the obligation requires and how to comply without it becoming a burden.
Are accountants obligated to AML?
It depends on the services provided. Accountants who work on activities such as setting up and changing companies, managing third-party funds, buying and selling property on a client's behalf or advising on certain operations are subject to AML obligations. The sector supervisor is the Federal Accounting Council (CFC), and suspicious operations are reported to COAF.
What the obligation requires
- AML policy: written procedures, proportional to the size and risk of the activity.
- Know Your Customer (KYC): identify and qualify the client and, for a company, understand the ownership structure and beneficial owner.
- Risk assessment: classify clients and operations by risk level and apply proportional diligence.
- Records: keep the data and the history of the checks.
- Reporting to COAF: report suspicious operations and file the annual non-occurrence report.
The non-occurrence report
A common point of confusion: even if there was no suspicious operation during the year, the accountant must file, once a year, the non-occurrence declaration. Failing to declare, thinking there was "nothing to report", is a common and avoidable mistake.
Where screening fits
To know the client and assess risk, you need to check whether the person or company appears on sanctions lists, as a politically exposed person (PEP) or in restrictions, and to understand the ownership links of any company. Doing this client by client, by hand, does not scale for a firm with dozens or hundreds of companies.
How Orvyan helps the accountant
Orvyan checks people and companies against sanctions, PEP and restriction lists, and maps ownership links (reverse ownership search), classifying the risk of each query. It can be used in the browser, with nothing to install and no coding, which serves the accountant with no IT team. Orvyan supports identification and risk assessment; the AML policy, the decision and the report to COAF remain with the accountant.