Suspicious Activity Reporting Policy in Financial Institutions: Risk-Based Approach and “Over-Reporting”
COAF (Conselho de Controle de Atividades Financeiras), or the Financial Activities Control Council, was established with the enactment of Law No. 9,613/98 as a Financial Intelligence Unit (“FIU”) endowed with a certain degree of independence in relation to investigative and judicial bodies. Its purpose was to regulate, investigate, and sanction conduct that indicated the practice of money laundering. Currently, COAF (Council for Financial Activities Control) operates as an autonomous entity,