Overview
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Brazil is a member of the United Nations. UN sanctions are automatically applied in Brazil through the Charter of the United Nations Act, Decree No. 19,841/1945. Under Law No. 13,810/2019, implemented by Decree No. 9,825/2019, sanctions imposed by UNSC resolutions (and designations made by its sanctions committees) apply immediately and directly in Brazil. This replaced the older system under the former Law No. 13,170/2015 (now revoked), under which each resolution had to be implemented by decree and asset freezes had to be obtained through the courts. The current framework has applied since Law No. 13,810/2019 came into force on 6 June 2019.
What the measures look like
The principal measure is the “unavailability of assets” (“indisponibilidade de ativos”, under Article 3 of Law No. 13,810/2019) – i.e. an asset freeze. It prohibits transferring, converting, moving, making available or otherwise dealing with the assets of a designated person or entity, directly or indirectly. Unavailability of assets does not transfer ownership of the assets to the State; it blocks dealings with them while the sanction is in force. UNSC resolutions may also require restrictions on entry to (or exit from) Brazil and restrictions on the import or export of goods.
Who must comply
The prohibition on breaching UNSC sanctions applies to all Brazilian people, legal entities and bodies in Brazilian territory, as well as public bodies. Financial institutions and other “obligated persons” listed in Brazil’s anti-money-laundering law (Law No. 9,613/1998) — such as banks and other financial institutions, securities brokers, insurers and dealers in high-value goods such as real estate and jewellery — must give effect to an asset freeze without delay and without prior notice to the sanctioned person, in the manner set by their regulator. Regulators in Brazil are:
- the Banco Central for financial institutions
- the CVM for securities firms
- the SUSEP for insurers or,
- COAF for sectors without a dedicated regulator.
No autonomous sanctions programme
Brazil does not operate its own autonomous sanctions programme.
Law No. 13,810/2019 does provide for what it calls the “national designation” of persons. This mechanism is confined to terrorism and its financing, rather than being a general tool that can be used on policy grounds (such as human rights or corruption).
National designations are triggered by a court order freezing the assets of a person investigated or accused of terrorism under the Anti-Terrorism Law (Law No. 13,260/2016), after which the Ministry of Justice and the Ministry of Foreign Affairs decide whether to designate the relevant person/entity. People added to the national terrorism list are then proposed to the relevant UN Security Council sanctions committee, who will consider whether to add them to the relevant sanctions list.
Law No. 13,810/2019 also requires the Ministry of Justice to keep a public list of those whose assets are subject to unavailability. No national designations have been made to date.
The Economic Reciprocity Law
Separately from the UN framework, the Economic Reciprocity Law (Law No. 15,122/2025), implemented by Decree No. 12,551/2025, gives the Brazilian Government legal authority to adopt “countermeasures” where a country or economic bloc adopts unilateral measures – such as tariffs – that negatively affect Brazil’s international competitiveness. The available countermeasures are trade and investment measures (for example, additional import duties, the suspension of trade concessions, and the suspension of certain intellectual-property obligations.
The grounds for acting are set out in Article 2. Article 3 lists the available countermeasures, which may be applied individually or together:
- a commercial duty on imports of goods or services,
- the suspension of intellectual-property obligations (under Articles 2 to 8 of Law No. 12,270/2010) and
- the suspension of other concessions or obligations under Brazil’s trade agreements – with the proportionality requirement in Article 1.
The Decree created the Interministerial Committee for Economic and Trade Negotiation and Countermeasures (CINCEC). The procedure for imposing countermeasures is:
- Diplomatic consultations led by Brazil’s Ministry of Foreign Affairs to try and resolve disputes by negotiation.
- In urgent cases, provisional countermeasures may be imposed by CINCEC, adopting a fast-track procedure.
- Permanent countermeasures may be adopted by Brazil’s Chamber of Foreign Trade after a public consultation.
The law was enacted against the background of additional United States tariffs on Brazilian exports. As of May 2026, Brazil has pursued consultations (including at the World Trade Organization) and bilateral negotiations, but no countermeasures have been adopted. An official summary is available from the Presidency of the Republic.
National Competent Authorities
The Ministry of Justice and Public Security (Ministério da Justiça e Segurança Pública), through its Department of Asset Recovery and International Legal Cooperation (DRCI), is the central authority for the domestic implementation of UNSC sanctions. It communicates new and updated UN lists to the financial regulators and to COAF, keeps the public list of persons and entities whose assets are subject to unavailability, and receives requests for delisting (csnu@mj.gov.br).
The Council for Financial Activities Control (COAF) is Brazil’s financial intelligence unit. Created by Law No. 9,613/1998 and restructured by Law No. 13,974/2020, it is housed within the Banco Central for administrative purposes, while keeping its own technical and operational independence. It receives and analyses suspicious-activity reports and communications relating to frozen assets, and disseminates financial intelligence to the competent authorities.
The Banco Central do Brasil (BCB) supervises financial institutions’ compliance, including the immediate implementation of UNSC asset freezes, through its anti-money-laundering and counter-terrorist-financing rules.
The Comissão de Valores Mobiliários (CVM), Brazil’s securities regulator, applies equivalent obligations to the entities under its supervision.
The Ministry of Foreign Affairs (MRE / Itamaraty) publishes UNSC resolutions in Brazil’s Official Gazette, communicates Brazil’s implementing measures to the relevant UN body, and leads the diplomatic consultations provided for under the Economic Reciprocity Law.
For export controls, the Interministerial Commission for the Control of Exports of Sensitive Goods (CIBES) – with the Ministry of Science, Technology and Innovation (MCTI) acting as its executive secretariat – controls sensitive and dual-use goods, while the Ministry of Defence controls defence products.
Legislation
Sanctions Lists
See the UN sanctions lists:
- UN Security Council Consolidated List – the operative list of designated persons and entities in Brazil (see our UN Sanctions Lists page).
For export-control purposes, Brazil also maintains national control lists of “sensitive” goods (see Export controls below).
Guidance
Licensing
Brazil does not operate a general system of sanctions licences or permits to authorise activity that would otherwise breach UN sanctions. There is no statutory exemption-licence mechanism. Where a person’s assets have been frozen, Law No. 13,810/2019 allows for the partial release of funds to meet certain basic or ordinary expenses; for persons listed by the UN Security Council, this is subject to the relevant UN sanctions committee not objecting within the period set by the relevant UN resolution; extraordinary expenses require the committee’s prior approval.
Enforcement
Breaching UN Security Council sanctions is prohibited under Law No. 13,810/2019. Brazil does not have a dedicated sanctions-breach offence; instead, conduct is addressed through a number of related regimes.
Terrorism and its financing are criminal offences under the Anti-Terrorism Law (Law No. 13,260/2016). Terrorism offences are punishable by 12 to 30 years’ imprisonment, and the financing of terrorism by 15 to 30 years’ imprisonment. Investigation of these offences falls to the Federal Police, prosecution to the Federal Public Prosecutor’s Office, and trial to the Federal courts.
Financial institutions and other obligated entities that fail to comply with freezing or reporting duties face administrative penalties from their regulators (the Banco Central and the CVM) and from COAF, under the anti-money-laundering and counter-terrorist-financing framework established by Law No. 9,613/1998.
Violations of export controls carry penalties under Law No. 9,112/1995.
Reporting
Financial institutions and other obligated persons must implement UN Security Council asset freezes without delay and report the frozen assets, and any attempted transfers, to the Ministry of Justice (DRCI), to their regulator and to COAF (Law No. 13,810/2019, article 11, together with the relevant Banco Central and CVM rules).
Separately, suspicious transactions – including those suspected of being linked to sanctions evasion or the financing of terrorism – must be reported to COAF as Brazil’s financial intelligence unit.
Export controls
Brazil controls the export of military goods and of “sensitive” goods – those in the nuclear, chemical, biological, missile and dual-use fields – and gives effect to UN arms embargoes. Exports of arms, ammunition and military equipment are prohibited to countries subject to UN economic sanctions, and Brazil also applies the Kimberley Process Certification Scheme to rough diamonds.
Legislation
Authorities and international regimes
Sensitive and dual-use goods are controlled under Law No. 9,112/1995 through the Interministerial Commission for the Control of Exports of Sensitive Goods (CIBES), whose executive secretariat is the General Coordination for Sensitive Goods (CGBS) at the Ministry of Science, Technology and Innovation (MCTI).
Brazil is a member of the Nuclear Suppliers Group (NSG) and the Missile Technology Control Regime (MTCR), and gives effect to the Chemical Weapons Convention and the Biological Weapons Convention. Brazil is not a member of the Wassenaar Arrangement or the Australia Group.
Defence products are controlled by the Ministry of Defence under the National Policy on the Export and Import of Defence Products (Decree No. 9,607/2018).
Export Control Lists
- National control lists for the nuclear, missile, chemical and biological / dual-use areas (maintained by CIBES / MCTI).
Licensing
Export authorisations for sensitive goods are assessed by the Ministry of Foreign Affairs and the MCTI and are submitted through the Single Window for Foreign Trade (Portal Único Siscomex), using the licences, permits and certificates (LPCO) module. The MCTI’s legal time-limit to grant clearance is 30 days; in practice straightforward applications are typically analysed within about 10 working days. Further detail is available from the MCTI’s page on the control of imports and exports of sensitive goods.
De-listing
A person or entity subject to UN sanctions in Brazil may seek removal by application to the Ministry of Justice (csnu@mj.gov.br). The Ministry, in coordination with the Ministry of Foreign Affairs, considers the request and, where appropriate, transmits it to the relevant UN sanctions committee. Persons listed directly by the UN Security Council may also apply to be de-listed through the UN itself (see our UN De-listing page).
Judgments
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ADPF1178/DF
