São Paulo

The São Paulo DARTE session took place on March 17th, 2026, at the World Trade Center, in collaboration with the European Commission, Asensi Abogados, Crypto Finance, Itaú, MERGE, and Sumsub. This edition brought DARTE to Latin America for its first dedicated session in Brazil, convening regulators, legal practitioners, and digital asset infrastructure providers to examine the regulatory and operational challenges at the intersection of LatAm and European frameworks.

The roundtable explored three interconnected themes shaping the future of the Brazil-EU regulatory corridor. The session opened with a welcome keynote by Stijn Vander Straeten, CEO of Crypto Finance Group, who framed the moment as a rare convergence of regulatory ambition, MiCA in Europe and Brazil's evolving crypto architecture developing in parallel, and made the case for international regulatory corridors as the structural foundation for sustainable cross-border digital asset flows. He also drew attention to the asymmetries created by uneven implementation across national authorities, where domestic players operating within an incomplete framework can find themselves disadvantaged against entities entering through passporting from better-established regimes.

Marina Villalonga (Asensi Abogados) opened the technical discussions with an analysis of the dual licensing challenge facing LatAm firms seeking EU market access, unpacking the structural overlap between MiCAR and PSD2 for EMT-related activities and presenting the operational models available to firms navigating this terrain. Maria Isabel Sica Longhi (Ripple) followed with an examination of Latin America's fragmented stablecoin landscape, making the case for a regional minimum standard developed through CEMLA as the foundation for consumer protection, supervisory credibility, and equivalence recognition under the GENIUS Act. Kat Cloud (Sumsub) closed the technical sessions with a discussion on Travel Rule harmonization, arguing that the region's compliance challenge is as much technical as it is regulatory, and that open interoperability protocols are a prerequisite for any meaningful convergence. The session concluded with a keynote by Giovana Fiorin Abreu (Itaú Unibanco), who reflected on the protectionist tendencies that have historically limited cross-border integration in the region and called for cooperation-based, practical solutions as the only credible path forward.

The São Paulo edition marked a significant expansion of DARTE's geographic reach, bringing its model of structured, expert-led regulatory dialogue to one of the world's most dynamic digital asset markets. As Latin America accelerates its regulatory development and the EU's MiCA framework matures, the session underscored the urgency of building the bilateral frameworks, shared standards, and institutional relationships that will determine whether the Brazil-EU corridor becomes a model for global regulatory cooperation — or remains an unrealized opportunity.

Full Report

Regulatory Issues for Payment Services from LatAm to the EU

The first session examined the structural challenges facing Latin American firms seeking to access the EU market, focusing on the regulatory overlap between MiCAR and PSD2 for e-money token activities. Participants discussed how the dual legal qualification of EMTs creates cumulative licensing obligations, and why reverse solicitation under MiCAR is not a viable path to scale for firms with active commercial models. The conversation contrasted the EU's framework with Brazil's activity-based approach and the GENIUS Act's equivalence mechanism, and assessed three operational models available to firms navigating the dual-regime terrain. The recent conclusion of PSD3 and PSR trilogue negotiations was noted as a relevant development, though participants observed that the dual-licensing issue persists in the interim.

Call to Actions

Develop a clear taxonomy for EMT-related activities, enabling firms to determine which regulatory regime applies and reducing interpretive divergence across Member States.
Advance NCA coordination and leverage the PSD3/PSR finalisation process to resolve the current regulatory superimposition of MiCAR and payment services rules.
Establish EU-LatAm regulatory cooperation frameworks exploring mutual recognition or equivalence mechanisms to reduce duplicative licensing requirements across jurisdictions.

The Lack of a Common LatAm Standard for Stablecoin Issuance

Call to Actions

The second session addressed the structural consequences of Latin America's fragmented stablecoin regulatory landscape, where each jurisdiction has developed its own framework independently, creating incentives for regulatory arbitrage and leaving consumers across the region with uneven protections. Participants examined how the absence of common reserve, redemption, and disclosure standards allows issuers to domicile in the lightest-touch regime while distributing products digitally across borders. The GENIUS Act's equivalence requirements were discussed as an additional commercial pressure on jurisdictions without credible frameworks. The session made the case for a regional minimum standard developed through CEMLA, drawing on MiCA and the FSB's global stablecoin recommendations as reference models.

Establish a regional minimum standard for stablecoin issuance through CEMLA, covering reserve requirements, redemption rights, and disclosure obligations, as a common floor for all participating jurisdictions.
Implement mutual recognition with an equivalence pathway, allowing compliant stablecoins to operate across borders and generating the equivalence record needed for access to US markets under the GENIUS Act.
Engage proactively with the FSB's global stablecoin work to ensure that international frameworks reflect the distinct economic function of stablecoins in high-inflation economies across the region.

Harmonizing Latin America's Fragmented Travel Rule

The third session examined why Travel Rule compliance in Latin America remains operationally fragmented despite growing regulatory momentum, arguing that the challenge is as much technical as it is regulatory. Participants identified the absence of open interoperability protocols between VASP compliance systems as the core bottleneck, and discussed the role of regulatory pressure in driving closed systems to open up. The asymmetry between traditional payments — where Travel Rule obligations are embedded invisibly in infrastructure — and crypto, where information exchange must precede settlement, was identified as a key structural difference requiring purpose-built solutions. Brazil's phased VASP framework was highlighted as a regional reference model, and the upcoming FATF standards revision was identified as a concrete opportunity for regional alignment.

Call to Actions

Develop model legislation and shared regulatory guidance through a regional coordination body, with active industry participation to ensure rules are technically implementable and proportionate.
Mandate open interoperability protocols for Travel Rule infrastructure, enabling VASPs to exchange compliance data across providers and jurisdictions rather than operating within closed proprietary systems.
Use the FATF revision cycle to anchor regional harmonization, coordinating national transposition processes to converge on common data standards, thresholds, and mutual recognition of VASP licensing.