Executive summary: Receita Federal, the Central Bank, and COAF have intensified monitoring of PIX transactions. Companies need clear flows to identify risks, monthly audits, and fast responses to prevent freezes, assessments, and reputational damage.
📋 Índice
Market benchmark: CNN Brasil coverage and Receita releases stress the increased oversight but lack reusable flowcharts or checklists. Our material combines legislation, response templates, and implementation guides that competitors do not provide.
How PIX monitoring works
The framework relies on specific regulations:
- BCB Resolution 103/2021 — obligations for payment institutions.
- RFB Ordinance 208/2024 — integrated monitoring between Receita, the Central Bank, and COAF.
- COAF Technical Note 05/2025 — warning signs and suspicious-transaction reporting guidelines.
Supporting sources: Serpro communications (2025) on the ARCA integration and Banco Central’s “PIX em Números” report (2024) help you calibrate alert thresholds.
Data flow
- Financial institutions send transaction data to the Central Bank.
- Suspicious data is shared with COAF and Receita (ARCA and data-analytics systems).
- Alerts are cross-checked against tax obligations, SPED, e-Financeira, and declarations.
Risk flow (key steps)
- Detection (internal or external) — transactions outside the profile, high values, anomalous frequency.
- Risk classification — low, medium, or high based on internal parameters and COAF guidance.
- Documentation — contracts, invoices, statements, service evidence.
- Response — submit documents, contracts, audit plans, remedial actions.
- Closure — transaction cleared or escalated for investigation/assessment.
Download the “PIX Monitoring Flowchart” to train your teams.
Competitive comparison: specialty portals usually provide only lists of warning signs. Our flowchart specifies response times, accountable parties, and integration points with internal systems, filling the implementation gap.
Monthly audit checklist
- Detailed bank reconciliation by cost center.
- Review transactions above defined thresholds.
- Verify KYC/KYB for counterparties.
- Archive documentation (contracts, invoices, service evidence).
- Record decisions and analyses (audit log).
Recommended tools: reconciliation dashboards, RPA to cross-check NF-e and bank statements, ERP integrations.
Benchmark: Finance consultancies quoted by Valor Econômico (Apr 2025) note that RPA adoption cut false positives by 35%. Use that KPI to assess your flow’s effectiveness.
Response templates for Receita/COAF
When notified, your response should include:
- Operation summary — amounts, dates, parties.
- Justification — transaction nature, contracts, invoices.
- Supporting evidence — PDFs, system screenshots, reconciliations.
- Prevention plan — controls in place, corrective actions, training.
Download the Receita/COAF response template (Word format).
Additional legal basis: PGFN/CAT Opinion 15546/2024 authorizes data sharing via agreements—cite it to reinforce legal compliance.
Technology and AI for compliance
- Deploy scripts to categorize transactions automatically.
- Create alerts based on risk patterns (unusual values, new counterparties).
- Integrate dashboards (Power BI/Data Studio) with risk and audit indicators.
- Use generative AI carefully for response drafts—always validate with legal teams.
Differential: while news pieces highlight Receita’s use of AI, we show how to replicate the structure internally with templates and SLAs.
Real cases and lessons
- Companies unable to prove source of funds saw accounts frozen for 72 hours.
- KYC/KYB failures triggered penalties for lack of diligence in payment chains.
- Firms with documented flows resolved cases in under 48 hours.
Frequently asked questions
- Which transactions trigger monitoring? Values above the profile, recurring transfers with new counterparties, relationships with high-risk entities.
- Must companies report suspicious operations? Yes, when they act as obligated institutions (e.g., fintechs) or detect atypical transactions.
Next steps
- Map and classify transaction patterns.
- Set up the monitoring flowchart and internal SLAs.
- Implement monthly audits and RPA reconciliations.
- Train finance/compliance teams with the templates provided.
- Review responses quarterly against COAF guidelines.
Need help deploying your PIX control tower? FDS Tributário delivers end-to-end implementation, from flowcharts and automation to response playbooks.
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