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e) Payments and open banking regulation. For payments, Brazil has both bank licenses and “instituição de pagamentos” (P.I.s), which can initiate and process payments, issue cards, and serve as on and off-ramps for various services. There are some other licenses for forex-only banks and other services. Brazil also adopted an open banking regulation, which is similar to PSD2 in Europe but arguably more efficient and has more mandatory elements.
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