---
title: "Brazil LGPD International Transfers"
canonical_url: "https://www.sorena.io/artifacts/latam/brazil-lgpd/international-transfers"
source_url: "https://www.sorena.io/artifacts/latam/brazil-lgpd/international-transfers"
author: "Sorena AI"
description: "Grounded Brazil LGPD transfer guide covering Articles 33 to 35, adequacy, ANPD standard contractual clauses, specific clauses, binding corporate rules."
published_at: "2026-02-21"
updated_at: "2026-02-21"
keywords:
  - "Brazil LGPD international transfer"
  - "Article 33 LGPD"
  - "ANPD standard contractual clauses"
  - "Brazil binding corporate rules"
  - "Brazil transfer adequacy"
  - "Brazil LGPD transfers"
  - "ANPD standard clauses"
  - "binding corporate rules Brazil"
---
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---

# Brazil LGPD International Transfers

Grounded Brazil LGPD transfer guide covering Articles 33 to 35, adequacy, ANPD standard contractual clauses, specific clauses, binding corporate rules.

*Transfer Guide* *Articles 33 to 35*

## Brazil LGPD International Transfers

Treat cross-border transfer as a separate compliance decision with its own mechanism, disclosures, and contracts.

You need both a valid domestic legal basis and a valid transfer mechanism. One does not replace the other.

Articles 33 to 35 and the ANPD transfer regulation require more than a contract label. First confirm that the activity is an international transfer, that LGPD applies to the underlying processing, and that the transfer has a valid legal basis. Then choose the transfer mechanism and meet the transparency and contract duties that go with it.

## Confirm that the activity is actually an international transfer

The ANPD transfer regulation distinguishes international transfer from international collection. A transfer exists when an exporter transmits, shares, or provides access to personal data to an importer in another country or to an international organization.

That analysis should include onward transfers and subprocessor chains, not only the first foreign recipient.

- Map exporter, importer, and onward recipient roles
- Separate true transfers from mere collection abroad where no transfer occurs
- Document the business purpose, data categories, and affected data subjects

## Choose the mechanism only after basis and scope are confirmed

The transfer regulation requires the controller to verify that the operation is supported by both a legal basis and a valid transfer mechanism. Valid mechanisms include adequacy recognition by ANPD, standard contractual clauses, specific contractual clauses, binding corporate rules, and other Article 33 cases that do not depend on regulation.

There is no hierarchy in principle, but some mechanisms can be used immediately while others require prior ANPD recognition or approval.

- Use adequacy where ANPD has recognized equivalent protection
- Use ANPD standard clauses in full and without modification when that route fits
- Use specific clauses or binding corporate rules only when the circumstances justify the added approval burden

*Recommended next step*

*Placement: after the scope or definition section*

## Use Brazil LGPD International Transfers as a cited research workflow

Research Copilot can take Brazil LGPD International Transfers from clarifying scope and applicability with cited answers to a reusable workflow inside Sorena. Teams working on Brazil LGPD can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

- [Open Research Copilot for Brazil LGPD International Transfers](/solutions/research-copilot.md): Start from Brazil LGPD International Transfers and answer scope, timing, and interpretation questions with cited outputs.
- [Talk through Brazil LGPD](/contact.md): Review your current process, evidence gaps, and next steps for Brazil LGPD International Transfers.

## Meet the transparency duties to data subjects

The controller must publish, on its website, a document in Portuguese, using simple, clear, precise, and accessible language, with information about the form, duration, and specific purpose of the transfer, the destination country, and the applicable rights and responsibilities.

Data subjects can also request the full text of the clauses used for the transfer, subject to commercial and industrial secrecy.

- Publish a transfer notice in Portuguese with the required elements
- Prepare a response path for requests to see the clause text
- Keep website disclosures aligned with the signed contract and actual data flow

## Operationalize ANPD clauses and BCR governance

ANPD standard contractual clauses must be adopted in full and can be embedded in a dedicated transfer agreement or as an addendum to a broader contract. Binding corporate rules are only valid for the entities and countries they actually cover and need a responsible entity in Brazil that answers for violations.

Both mechanisms need a process for updates, changes, legal conflicts, and rights handling within the deadlines already recognized by LGPD.

- Track version control for contracts, addenda, and BCR documents
- Create a legal-change process for foreign law conflicts and safeguard failures
- Link transfer terms to incident, rights, and vendor oversight workflows

## Primary sources

- [Lei No. 13.709/2018 (LGPD)](https://www.planalto.gov.br/ccivil_03/_ato2015-2018/2018/lei/l13709.htm?ref=sorena.io) - Primary legal text for Articles 33, 34, 35, 36, and 37.
- [ANPD home page](https://www.gov.br/anpd/pt-br?ref=sorena.io) - Official ANPD portal used for transfer regulation updates and publication context.
- [Resolution CD/ANPD No. 2/2022](https://www.in.gov.br/en/web/dou/-/resolucao-cd/anpd-n-2-de-27-de-janeiro-de-2022-376562019?ref=sorena.io) - Official ANPD rule for small-scale processing agents and high-risk criteria relevant to transfer governance.

## Related Topic Guides

- [ANPD Enforcement and Fines | Brazil LGPD Inspection, Procedure, and Sanctions](/artifacts/latam/brazil-lgpd/anpd-enforcement-and-fines.md): Grounded ANPD enforcement guide covering inspection procedure, sanctions progression, Article 52 factors, Resolution CD ANPD No.
- [Brazil LGPD Applicability Test | Article 3 Scope, Article 4 Exclusions, Roles](/artifacts/latam/brazil-lgpd/applicability-test.md): Grounded Brazil LGPD applicability test covering Article 3 territorial reach, Article 4 exclusions, controller versus operator allocation.
- [Brazil LGPD Checklist | Scope, Rights, Incidents, Transfers, Evidence](/artifacts/latam/brazil-lgpd/checklist.md): Audit-ready Brazil LGPD checklist covering scope, role allocation, lawful bases, rights timing, DPO disclosure, security, incident reporting.
- [Brazil LGPD Compliance Program Guide](/artifacts/latam/brazil-lgpd/compliance.md): Build a grounded Brazil LGPD compliance program around scope, lawful bases, rights, records, incident reporting, transfers, DPO, and ANPD-ready evidence.
- [Brazil LGPD Data Subject Rights | Articles 18 to 20 and 15 Day Access Rule](/artifacts/latam/brazil-lgpd/data-subject-rights.md): Grounded Brazil LGPD rights guide covering Articles 18 to 20, free requests, immediate simplified confirmation, full access declaration within 15 days.
- [Brazil LGPD Deadlines and Compliance Calendar](/artifacts/latam/brazil-lgpd/deadlines-and-compliance-calendar.md): Brazil LGPD compliance calendar covering key legal and ANPD milestones plus recurring duties for rights, incidents, transfers, training.
- [Brazil LGPD DSAR Response Template | Immediate and 15 Day Response Logic](/artifacts/latam/brazil-lgpd/lgpd-dsar-response-template.md): Use a Brazil LGPD DSAR response template aligned to Articles 18 and 19, immediate simplified response, full declaration within 15 days, denial rationale.
- [Brazil LGPD FAQ | Scope, Rights, Incidents, Transfers, Enforcement](/artifacts/latam/brazil-lgpd/faq.md): Practical Brazil LGPD FAQ answering common scope, lawful basis, rights, incident, transfer, DPO, and enforcement questions using the law and ANPD guidance.
- [Brazil LGPD Incident Reporting and Breach Notification](/artifacts/latam/brazil-lgpd/breach-notification.md): Grounded Brazil LGPD incident reporting guide covering Article 48, ANPD Resolution CD ANPD No.
- [Brazil LGPD Lawful Bases | Article 7, Article 11, Legitimate Interest](/artifacts/latam/brazil-lgpd/lawful-bases.md): Grounded Brazil LGPD lawful basis guide covering Article 7 and 11 bases, consent rules, ANPD legitimate interest guide, sensitive data.
- [Brazil LGPD Penalties and Fines | Article 52 and ANPD Dosimetry](/artifacts/latam/brazil-lgpd/penalties-and-fines.md): Grounded Brazil LGPD penalties guide covering Article 52 sanctions, 2 percent fine cap, R$50 million limit per infraction, publicization, blocking, deletion.
- [Brazil LGPD Requirements | Articles, Controls, Evidence, and ANPD Guidance](/artifacts/latam/brazil-lgpd/requirements.md): Operational Brazil LGPD requirements map covering scope, lawful bases, transparency, rights, records, DPO, security, incidents, transfers.
- [Brazil LGPD Templates | DSAR, Incident, Basis, Transfer, Governance](/artifacts/latam/brazil-lgpd/templates.md): Practical Brazil LGPD template library priorities covering DSAR responses, incident communications, lawful basis records, transfer assessments.
- [Brazil LGPD vs CCPA and CPRA | Structure, Rights, Enforcement, and Reuse](/artifacts/latam/brazil-lgpd/lgpd-vs-ccpa.md): Grounded comparison of Brazil LGPD and CCPA or CPRA covering scope logic, legal basis model, rights timing, cross-border governance, and reusable controls.
- [Brazil LGPD vs GDPR | Similarities, Differences, and Control Reuse](/artifacts/latam/brazil-lgpd/lgpd-vs-gdpr.md): Grounded comparison of Brazil LGPD and GDPR covering scope, lawful bases, rights timing, DPO rules, transfer mechanisms, incident reporting.


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