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regulatory / legal

Legal and Governance

IMFB operates with a focus on ethical financial practice, responsible commercial conduct, regulatory awareness and Shariah-conscious transaction principles.

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Our governance approach is designed to support transparency, appropriate client due diligence, clear contractual arrangements, responsible partner selection and careful coordination of financial, trade, investment and commercial services.

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IMFB’s activities may involve cooperation with external service providers, including payment institutions, custodians, escrow providers, legal advisers, accountants, technology providers, compliance advisers, Shariah advisers and other specialist partners.

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Where a service requires specific regulatory permission, professional qualification, legal authorisation or third-party provider approval, IMFB will seek to ensure that the service is delivered through the appropriate framework and subject to applicable requirements.

Governance Priorities

  • Ethical and Shariah-conscious commercial practice

  • Client due diligence and onboarding controls

  • Anti-money-laundering and counter-terrorism-financing awareness

  • Sanctions and prohibited-activity screening

  • Responsible partner and service-provider selection

  • Appropriate legal and regulatory review

  • Clear client disclosures and service terms

  • Data privacy and information-security controls

  • Transaction monitoring and commercial risk review

  • Ongoing review of products, services and partner arrangements

 

Legal Notice

The information on this website is general in nature and does not constitute legal, tax, investment, financial, regulatory or Shariah advice.

Clients, investors and partners should obtain their own independent professional advice before entering into any transaction, investment, product, service or commercial arrangement.

Regulatory and Platform Disclosure

IMFB is a financial-services, trade-support, market-entry and commercial-coordination platform.

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IMFB operates a white-label digital financial services platform under a Banking as a Service — BaaS model.

Under this structure, IMFB controls the customer-facing brand, application interface, digital experience, commercial offerings and technology integrations. The platform is presented to customers using IMFB’s own branding, visual identity, domain, application design and service channels.

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The regulated financial and payment infrastructure supporting the platform is provided through integration with the systems and application programming interfaces — APIs — of a our partner Financial Institutions duly authorized to operate by the Central Bank of Brazil.

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IMFB does not represent itself as a bank, deposit-taking institution, payment institution, securities dealer, investment manager, foreign-exchange institution, custodian, escrow provider, insurer or financial adviser unless expressly authorised to do so under applicable law and confirmed in the relevant client documentation.

Certain services described on this website may be delivered by, or in cooperation with, appropriately licensed, authorised or regulated third-party providers.

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These may include services relating to:

  • Payment accounts

  • Payment initiation

  • Pix functionality

  • Card services

  • Cross-border payments

  • Foreign exchange

  • Custody

  • Escrow

  • Investment administration

  • Financial products

  • Credit or asset finance

  • Insurance

  • Digital assets

  • Transaction reporting

  • Identity verification

  • Compliance screening

 

The relevant provider, its role, contractual terms, regulatory status and client eligibility requirements will be disclosed where required before any regulated service is activated or transaction is entered into.

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Important Platform Limitation

IMFB’s platform role may include client introduction, commercial coordination, transaction support, market access, financial-services coordination, technology interface, reporting support and relationship management.

This does not mean that IMFB itself performs every regulated function appearing on the platform.

Where applicable, regulated services are provided by authorised institutions or specialist providers operating under their own legal, regulatory and contractual obligations.

BaaS-enabled digital financial services platform

IMFB operates a BaaS-enabled digital financial services platform through a contractual and technological integration with a Financial Institution or Payment Institution authorized by the Central Bank of Brazil.

 

IMFB acts as the commercial platform operator, technology integrator and BaaS service-taking entity, while all regulated financial and payment services are provided by, booked with and remain under the regulatory responsibility of the authorized partner institution.

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This structure enables IMFB to deliver an integrated digital banking experience under its commercial platform while preserving the required regulatory separation, transparency and accountability between IMFB and the relevant authorized institutions.

Digital Financial Services Platform

IMFB is structured as a white-label digital financial-services platform supporting businesses, investors, suppliers, trade partners and overseas companies operating in or with Brazil.

The platform is intended to provide a coordinated digital interface for selected corporate financial services and commercial-support functions.

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Platform Capabilities May Include

  • Cash-management support

  • Treasury coordination

  • Payment workflow visibility

  • Supplier-payment coordination

  • Receivables monitoring

  • Transaction reporting

  • Client onboarding workflows

  • Document and transaction coordination

  • Trade-settlement support

  • Custody-provider coordination

  • Escrow-provider coordination

  • Cross-border financial coordination

  • Investor and transaction reporting

  • Concierge and client-service coordination

 

White-Label Platform Model

IMFB’s white-label model allows selected services to be accessed through an IMFB-branded client experience while the regulated components may be provided by authorised third-party institutions.

This model is intended to combine:

  • IMFB’s client relationship and commercial coordination

  • IMFB’s Islamic-finance and ethical-finance positioning

  • IMFB’s trade, investment and market-entry focus

  • The infrastructure and authorisations of appropriate regulated providers

  • The operational support of technology and compliance partners

 

The availability of any service may depend on provider approval, regulatory requirements, client eligibility, jurisdiction, product type, risk assessment and due-diligence outcomes.

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No Deposit-Taking Representation

Unless expressly stated in formal documentation issued by an appropriately authorised institution, funds accessed or managed through the platform should not be treated as deposits with IMFB.

IMFB does not hold itself out as a deposit-taking institution.

Brazilian Regulatory Framework

IMFB is designed to operate within the applicable Brazilian legal and regulatory environment.

Depending on the product or service, relevant Brazilian frameworks may include rules and requirements relating to payment arrangements, payment institutions, Pix, foreign exchange, capital markets, consumer protection, data protection, anti-money laundering, counter-terrorism financing, sanctions, tax, commercial law and digital-service delivery.

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The Banco Central do Brasil defines a payment arrangement as the set of rules and procedures governing the provision of a payment service to the public. The Banco Central also describes payment institutions as legal entities that enable purchase, sale and movement of funds within a payment arrangement, without granting loans or financing to their clients.

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Payment institutions are distinct from financial institutions and cannot carry out activities reserved for financial institutions, such as lending and financing, while still being subject to Banco Central supervision.

Relevant Regulatory Areas

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IMFB and its service providers may need to consider requirements issued or supervised by:

  • Banco Central do Brasil

  • Conselho Monetário Nacional

  • Comissão de Valores Mobiliários, where applicable

  • Conselho de Controle de Atividades Financeiras, where applicable

  • Receita Federal do Brasil, where applicable

  • Brazilian consumer-protection authorities

  • Brazilian data-protection authorities

  • Applicable courts, registries and commercial authorities

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Data Protection

Personal data collected or processed through the IMFB platform may be subject to Brazil’s Lei Geral de Proteção de Dados Pessoais, commonly known as the LGPD. The LGPD is Brazil’s general personal-data protection law and applies to the processing of personal data in relevant circumstances.

IMFB may collect and process personal or business information for purposes including onboarding, identity verification, compliance screening, client support, transaction coordination, fraud prevention, legal obligations, contractual performance and platform operation.

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Further information should be set out in IMFB’s Privacy Policy.

Payment Services and Pix

Pix is Brazil’s instant payment system created by Banco Central do Brasil. It allows transfers and instant payments between accounts in seconds, at any time and on any day.

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Any Pix, payment, payment-account, transfer, card, payment-initiation or transaction-processing functionality made available through IMFB will be subject to the rules, eligibility requirements, security controls and operating procedures of the relevant authorised provider.

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IMFB may support the client relationship, commercial coordination, user interface, reporting, onboarding or transaction workflow, but Pix and regulated payment services will be provided only through the appropriate authorised or eligible provider arrangements.

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Payment Service Availability

Payment services may be subject to:

  • Client identity verification

  • Corporate and beneficial-ownership checks

  • Provider onboarding approval

  • Transaction limits

  • Security and fraud-prevention controls

  • Anti-money-laundering screening

  • Sanctions screening

  • Tax and regulatory checks

  • Transaction monitoring

  • Platform availability

  • Provider rules and terms

  • Banco Central do Brasil requirements

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Pix Participation and Provider Rules

Banco Central do Brasil maintains rules and procedures relating to Pix participation, operating requirements, participant responsibilities and technical procedures. It also provides information on who may participate in Pix and the available participation modalities.

Where Pix is made available through the IMFB platform, clients should understand that:

  • Pix access may depend on the relevant provider’s participation model

  • Pix keys and account details may be subject to verification requirements

  • Transactions may be delayed, rejected or reviewed for security or compliance reasons

  • Limits may apply

  • Additional information may be requested before or after a transaction

  • Provider terms and Brazilian regulatory requirements will apply

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Payment Risk Notice

Payment functionality may be unavailable, interrupted, restricted or delayed due to technical issues, regulatory requirements, security reviews, provider outages, transaction monitoring, suspected fraud, incorrect details, compliance checks or circumstances outside IMFB’s control.

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Clients are responsible for confirming payment details before authorising any transaction.

IMFB and its providers may not be able to reverse a completed payment except where permitted by applicable rules, provider procedures or law.

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