An article from Transparency International on 23rd July says that a decision in one case before the Supreme Court has halted most of the country’s money laundering investigations.  The decision threatens one of the most important investigative tools against corruption and leaves Brazil at odds with the international AML regime.  The case involved the sharing of STR data by the country’s FIU (COAF) with the Brazilian Public Prosecutor’s Office investigating the Senator Flávio Bolsonaro (the President’s son) and his assistant.  The Court said COAF could only share generic data, such as the name of the account holder and total amounts received, but not details of the transactions without a court order due to bank secrecy rules.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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