As Brazil strengthens the integrity of its financial institutions through improved compliance policies, the National Monetary Council (CMN) has published Resolution No. 4,595. At the forefront of this new movement is Brazil’s top legal advocate, Bruno Fagali.
Bruno Fagali is spearheading Brazil’s pro-compliance and ethics policies by providing expert legal council and implementation. Bruno Fagali’s passion and constant striving to improve Brazil’s legal system has propelled him to the top. He is a member, founder and partner of the Fagali Advocacia, his own law firm. Bruno Fagali’s office is located in Sao Paulo and it specializes in public and electoral anti-corruption. His success is derived from his self-motivated attitude toward improving Brazil’s ethics, integrity and overall public image. His ability to deliver results and implement policies promptly and strictly has gained him the reputation of being one of the best legal practitioners in Brazil.
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Resolution No. 4595 applies to financial institutions and other institutions that are approved by the Central Bank of Brazil. Bruno Fagali also mentioned that the Resolution does not apply to Consortium administrators or payment institutions. Credit Union compliance policies must be agreed upon at the general meeting. It must be mentioned that the division responsible for overseeing the compliance functions must be entirely separate from any internal auditing processes.
Bruno Fagali has stated that the Resolution has provided measures for how institutions should conform to the new policies. This includes the division of activities when implementing the compliance functions in order to avoid conflicts of interest.
It is also important for institutions to understand that they must keep a minimum of five years of reports obtained from the compliance functions on hand. These documents must be brought forth whenever the Central Bank of Brazil requests them. Bruno Fagali has clearly and publically stated that the final deadline for implementing Resolution 4595/17 for all institutions that are subject to the new Resolution is December 31st, 2017.