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Brazilian Payment Regulation
By Philipp Bock and Bruno Balduccini
Over recent weeks, several e-commerce merchants and institutional providers have approached allpago and asked why they are no longer able to transact with customers in Brazil using the popular Boleto Bancário post-payment service.
Legislation introduced by the Central Bank of Brazil in 2016 to regulate the growing number of cross-border transactions created a new set of rules for providers facilitating payments with companies based overseas. The full details of this are available in the Central Bank’s Circular number 3691 as amended.
Article 132 of Circular 3691 sets forth that international payment facilitators can only accept payments from customers acquiring goods and services through their platforms using debit and credit cards issued in the name of the acquiring client, or through wire transfers coming from the acquiring client.
The logic of the rule is to have a clear identification of the origin of the funds and, consequently, avoid money laundering. The rule was issued based in the old Boleto rules whereby identification of the payer was not possible. Notwithstanding this fact, some international payment facilitators took a more aggressive interpretation of the rule and accepted Boletos.
More recently, the Central Bank has (allegedly) informed the market that Boletos would not be allowed for payment facilitators. Some providers have withdrawn Boletos as a payment option from their services as a consequence.
allpago, which uses a different legal structure to allow the use of Boletos, was unaffected by these enforcement measures. This means that e-commerce merchants and institutional providers based outside of Brazil can still accept payment by Boletos by connecting to allpago’s payment gateway.
Additional rules around the registration of Boletos in Brazil
The rules introduced by the Brazilian Central Bank in 2016 are not the only ones to have affected the use of Boletos in Brazil. The Brazilian Federation of Banks (FEBREBAN) introduced a compulsory registration scheme for Boletos on 14 February 2017 as part of efforts to reduce fraud and boost payment rates.
Following a phased introduction of the new scheme throughout 2017, Boletos now need to be registered by the issuer with the Brazilian Central Bank at the point they are created. Previously, the Central Bank may only have become aware of the Boleto at the point at which it was presented for clearing.
While this may seem like a small change, its impact is significant, providing the Central Bank and Boleto issuers with more information about Boletos in circulation, and giving customers a much greater amount of flexibility around how and when they use their Boletos.
The introduction of these new rules did work entirely in the customer’s favor. When registering new Boletos with the Central Bank became mandatory, many Boleto issuers in Brazil began applying a charge for doing so.
allpago’s payment platform is connected directly to the API and central billing system used to administer Boletos. It has always registered new Boletos created through allpago directly with the Central Bank itself. Unlike other issuers, allpago only charges for clearing Boletos – it does not apply a fee for creating and registering them.
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