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gateCOAF — Brazil AML / KYC Decision Gate
// IMMO.QUICK · GATECOAF · LEI 9.613/1998 · BACEN · CVM

Ten years, just like Switzerland.

gateCOAF forensically seals that a Brazilian institution passes thirteen parameters of Lei 9.613/1998, with COAF filing, BACEN/CVM alignment, and a ten-year retention period. Support for Brazilian financial institutions, never a replacement for COAF's own recognition.

In one sentence: gateCOAF checks thirteen parameters of Brazilian anti-money-laundering law and holds the same ten-year retention period as Switzerland, the longest among the South American and European jurisdictions in the system.
✓ RELEVANT IF...
  • You are a Brazilian financial institution under BACEN or CVM supervision
  • You need to demonstrably document the COAF filing (Comunicação de Operação Suspeita)
✕ NOT RELEVANT IF...
  • You expect COAF to automatically recognise the result as a complete filing
  • No Brazilian institution or duty under Lei 9.613/1998 is involved
// The problem

Three regulatory structures, BACEN, CVM, and COAF, must not blur together in a single check.

The Central Bank of Brazil, the Securities and Exchange Commission of Brazil, and the Council for Financial Activities Control have different mandates. gateCOAF checks alignment with all three separately, rather than merging them into a generic supervisory check.

The 50,000 BRL threshold as its own, transaction-bound cluster
The transaction threshold under Lei 9.613 is 50,000 BRL, independent of the EUR/CHF/SGD thresholds of other jurisdictions. The gate checks this value as its own hardcoded building block.
// Architecture

4 clusters, checked sequentially.

Every cluster is dispositive (material_block_mode: true), a hit blocks bindingly, not merely for documentation.

CLUSTER 1
CDD & Compliance Structure
Checks customer due diligence at 50,000 BRL or more and a documented internal compliance structure.
cdd_50000brl · compliance_structure
CLUSTER 2
COAF Filing
Checks the Comunicação de Operação Suspeita, the Brazilian equivalent of an STR, in cases of suspicion.
coaf_filed_if_required
CLUSTER 3
BACEN / CVM Alignment
Checks alignment with the central bank's and the securities regulator's requirements separately.
bacen_aligned · cvm_aligned
CLUSTER 4
Sanctions Screening & Retention
Checks the combined BACEN/UN sanctions list and the 10-year retention period.
bacen_un_screened · retention_10y
No case, no doubt
Every cluster returns its own sealed result. A single hit in an active cluster is enough to block the overall action.
// Test results

Two tested scenarios.

All values on this page are fictional test data and serve only to illustrate the gate logic.

Scenario C1C2C3C4 Verdict Latency
Full compliance (13/13)PASSPASSPASSPASSCOAF_SEALED311ms
4 critical violationsFAILFAILnot evaluatednot evaluatedBLOCK_COAF_10_FLAGS306ms
Cryptographic chain continuation
Every test produces a deterministic receipt_id, an input_snapshot_hash, an HMAC-SHA256 signature, and a merkle_link to the previous receipt. Persistence occurs in the gateCOAFReceipt entity with a 10-year retention period.
// Clarification

What gateCOAF is not.

  • Not automatic recognition by COAF, BACEN, or CVM. The gate delivers a cryptographic proof, not regulatory confirmation.
  • Not a replacement for the actual COAF filing. The gate seals the pre-check, it does not itself file with the authority.

For Brazilian financial institutions that want to make triple regulatory alignment provable.

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