Economy February 6, 2026

Finance Ministry Seeks Rules Fix to Stop Asset Concealment via Pooled and Escrow Accounts

Officials warn current measures fall short as fintech-style accounts evade judicial freezes and complicate public debt recovery

By Caleb Monroe
Finance Ministry Seeks Rules Fix to Stop Asset Concealment via Pooled and Escrow Accounts

Brazil's Finance Ministry has flagged gaps in banking rules that allow suspects to shield assets in pooled and escrow accounts, urging the central bank to tighten regulation after recent police operations and internal reviews revealed continued vulnerabilities. Authorities say existing rule changes only reduce, but do not eliminate, the risk to asset traceability and judicial freezes.

Key Points

  • Finance Ministry asked the central bank to close loopholes that allow concealment of assets in pooled and escrow accounts - impacts public finance and tax recovery.
  • Central bank tightened fintech and virtual-asset rules in November, but the Finance Ministry says those steps only reduce, not eliminate, the risks - affects fintech and banking sectors.
  • Investigators suspect a specific case involving Refinaria de Petroleos de Manguinhos (Refit), where more assets may exist beyond the 1.2 billion reais already frozen - relevant to petroleum/refining sector and tax enforcement.

Brazil's Finance Ministry has formally asked the central bank to address regulatory loopholes that, officials say, enable criminal and tax-evasion suspects to conceal assets in certain types of bank accounts and thereby sidestep court-ordered freezes intended to recover public funds, according to two sources and a Finance Ministry document.

The ministry's submission contends that pooled accounts - which aggregate funds from multiple beneficiaries - and escrow accounts, originally intended as temporary pass-through mechanisms, have been used to frustrate judicial efforts to locate and seize assets from individuals and companies under investigation.

Both the central bank and the Finance Ministry declined to comment on the matter.

Regulatory change perceived as insufficient

In November, the central bank strengthened rules aimed at fintechs and virtual-asset operators, including a requirement that pooled accounts be closed when they are used to provide unauthorized financial services or to conceal assets. The Finance Ministry, however, argued in its submission that the November measures only mitigate the problem and do not remove the underlying risks.

The ministry warned that pooled accounts continue to hamper the recovery of public debt, reduce traceability of funds and weaken efforts to combat money laundering. Investigators and ministry officials said pooled accounts can obscure the identity of ultimate beneficiaries from the national financial registry and fall outside mechanisms that allow the judiciary to freeze assets.

Similarly, escrow accounts that fintechs increasingly offer as if they were regular current accounts appear to be outside standard freeze systems, complicating attempts to follow the movement of funds and to block resources linked to investigations.

Specific investigation highlighted

One source involved in the inquiries told officials they suspect concealment of assets related to Refinaria de Petroleos de Manguinhos (Refit), a company currently under investigation for alleged multibillionaire tax fraud. Authorities say Refit may hold amounts beyond the 1.2 billion reais already frozen, but the additional resources have not been located.

Refit did not immediately respond to a request for comment.

Implications for enforcement

The Finance Ministry document and the sources cited in the ministry's filing emphasize that the persistence of pooled and escrow account structures undermines judicial asset-freeze tools and poses challenges to efforts to recover public funds and enforce tax collection. The ministry urged the central bank to adopt further regulatory clarifications or controls to ensure these account types cannot be misused to hide assets from investigators.

Currency conversion noted in ministry filings places $1 at 5.2312 reais.

Risks

  • Pooled accounts can obscure ultimate beneficiaries from the national financial registry, hampering traceability and judicial freezes - risk to law enforcement and public debt recovery operations.
  • Escrow accounts offered as current accounts by fintechs appear to fall outside asset-freezing mechanisms, limiting authorities' ability to block suspect funds - risk to banking oversight and anti-money-laundering efforts.
  • The Finance Ministry considers recent central bank measures insufficient, leaving ongoing vulnerabilities that could continue to enable asset concealment - regulatory uncertainty for fintechs and compliance departments.

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