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INR Registration Maintenance — Non-Resident Investor

Periodic registration update for Non-Resident Investors, under the responsibility of the representative in Brazil, with CVM registration where applicable, under Joint Resolution BCB/CVM No. 13 (Brazil's new foreign-exchange legal framework — Law 14,286/2021), which replaced Resolução CMN 4.373/2014.

Filing Deadline

Periodic update and upon any relevant registration change

Frequency

Annual

What it is

Non-Resident Investors (INRs) investing in Brazilian funds must appoint a representative in Brazil and, where applicable, register with the CVM (individuals are exempt from registration if they meet the registration requirements), keeping the registration current and updated upon any relevant change (address, ultimate beneficial owner, qualification, jurisdiction). The registration underpins tax treatment, FATCA/CRS and the provision of information to the CVM and the BCB (the Brazilian Central Bank). The regulatory basis, previously Resolução CMN 4.373/2014, is now Joint Resolution BCB/CVM No. 13, in force since January 1, 2025, which implements Law 14,286/2021 and, among other changes, abolished the RDE-Portfolio registration and the requirement to appoint a custodian prior to the start of operations.

Who must comply

Representatives and custodian institutions serving INRs and fiduciary administrators that receive investments from INRs. It covers individuals, legal entities and foreign investment funds.

Penalties for non-compliance

The INR's operations are blocked until the registration is regularized, with fines for non-compliance with the foreign-exchange and foreign-capital rules (Joint Resolution BCB/CVM No. 13) and exposure to FATCA/CRS sanctions.

How Arkar automates it

A dedicated INR module: full registration (individuals, legal entities, foreign funds), update workflows, integration with representatives and custodians, and provision of information to the CVM/BCB.

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