On behalf the EC Sub-Committee, consisting in the Egmont Group Committee Chair, the Acting Chair of the Membership Support and Compliance Working Group and the Regional Representatives for the Americas Region

Dear HoFIU,

Last 15 January 2019 FIU Brazil (COAF) informed the Egmont Group Secretariat about changes in the Law 9.613/98 from 1998 that establishes the FIU.  Moreover, Article 72 of the Medida Provisoria Nro. 870 from 1 January 2019 amends the following provisions of the Law 9.613/98 from 1998 that establishes the FIU:

• Article 14: COAF is “transferred” from the jurisdiction of the Ministry of Finance to the one of the Ministry of Justice and Public Security.
• Article 16: The list of public entities members of COAF is expanded.  

Taking into consideration what is stipulated in the Addendum to the Membership Procedure, this required the work of an EC Sub-Committee formed by: 

• Chair of the EC
• Chair of the MSCWG
• Regional Representatives (in this case, the Americas)

After reviewing the information provided by COAF, the EC Sub-Committee concluded that there are no fundamental changes in the amended articles 14 and 16 of the Law 9.613/98 that may affect the membership of COAF and its connection to the ESW.

The above-mentioned decision has been taken in accordance with Addendum to the “Egmont Group Membership Procedure” as read with the “Egmont Group Support and Compliance Process”.

For your reference, please find attached the following documents: 

• ESW communication sent by COAF informing about the changes.
• Law 9.613/98 from 1998 that establishes the FIU (in English), which contains relevant articles 14 and 16.
• New Medida Provisoria Nro. 870 from 1 January 2019 (in Portuguese), which article 72 amends articles 14 and 16 of Law 9.613/98.
• A comparative Chart prepared by COAF with the “before and after” versions of Articles 14 and 16 (here the English version of both provisions can be found).
• Current and upcoming organizational charts of COAF

Best regards,

EC Sub-Committee