Bruno Fagali Breaks Down Latest CMN Compliance Propositions

A new monetary standard was recently issued and published by the National Monetary Council (CMN). According to Bruno Fagali, a member Fagali Advocates and a compliance specialist, the new standard will affect all institutions authorized by the Central Bank of Brazil. The new rules, however, do not necessarily affect payment institutions and consortium managers as separate guidelines have been set aside for them. Bruno Fagali further breaks it down that to modernize and strengthen financial institutions compliance structures Monetary Council issued resolutions, 4595, 4557/17, and 4588/17, are used.

Bruno Fagali contends that this puts the responsibility of preparing the compliance mechanism squarely in the hands of the Board of Directors of the various banking institutions. For the credit unions, the compliance mechanisms must be approved at the next annual general meeting. For all cases, the board must ensure that the compliance committee is not the same as the internal audit committee. Besides, the compliance policy developed must correspond to the size, structure, risk profile, complexity, business model, and nature of the implementing institution.


For compliance purposes, Bruno Fagali emphasizes that the standard gives players a minimum compliance layout that they must meet. The compliance policy must clearly define the scope of the compliance mechanism to be in place, define specific roles to be played by officials implementing the policy, file the policy framework with the Central Bank, and file the actual policy implementation report with the bank for five years.

Bruno Fagali is a founding partner of the Fagali Advocacy law firm. He is widely respected as a top compliance practitioner in Brazil. He specializes in many aspects of the legal profession including public law, anti-graft law, administrative law, regulatory law, bidding law, civil liability processes, administrative improbity actions, and urban law.

Bruno also works with Nova/sb where he serves as the Corporate Integrity Manager. At Nova/sb he has set in motion an integrity program that ensures the company meets its corporate governance objects. He has also helped put in place a working mechanism that eliminates discriminatory practices between employees of different levels.

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