Resolution 4,595 Explained by Bruno Fagali

The National Monetary Council on August 30th published Resolution Number 4,595 which addresses the compliance policies of institutions and financial institutions that are allowed to operate by the Central Bank of Brazil. These new rules do not apply to payment institutions and consortium institutions. To learn more about this information, lawyer Bruno Fagali goes over all the information.

Bruno Fagali states that the resolution is added to new framework established by CMN. This is for risk management and helping to strengthen and modernize the compliance structure of all the institutions. The compliance policy should be approved by the board of directors. The board will have many responsibilities in the implementation of the compliance policy as well as the management of the policies. Credit Unions must have a compliance policy approved at a general meeting. The unit that is responsible for the compliance will have to be separated from any internal audit.


Bruno Fagali states that the Resolution allows for minimum parameters such as the scope of the compliance function as well as the objective. It allows for the clear division of responsibilities as well as avoiding conflicts of interest. It also allows for coordinating activities with risk management, internal audits and compliance functions.

The institutions subject to the resolution must be kept at the disposal of the Central Bank of Brazil. The Board of Directors of each institutions must keep records and all documentation be approved. This documentation must be kept for a minimum of five years. The Resolution also allows for hiring specialist to carry out any activities that are needed for the compliance responsibilities. This is also acceptable in the case where there is no board of directors.

Lawyer Bruno Jorge Fagali

Bruno Fagali is one of the most popular lawyers in Brazil. He has many years of administrative law experience and has made quite the reputation for himself. He has been in a variety of different law firms since 2006 and has experienced many different law mediums. He is now the Corporate Integrity Manager at Nova/SB and practices law through his own firm which is called Fagali Law Firm.

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