November 3, 2025
The term bump account has gained traction in Brazil recently, especially after new regulatory norms from the Central Bank of Brazil (BC) aimed at curbing fraud, money laundering, and opaque financial channels. Knowing what a bump account is is no longer just a technical curiosity — it is a requirement for companies, fintechs, and anyone using payment account services.
Simple definition
The bump account is a bank account or payment institution account that concentrates the resources of various end users in a single holder — usually the fintech or the institution providing the service — instead of opening an individualized account for each client.
In other words: several clients deposit or move amounts, but only the name of the fintech or institution appears in the statement, and not each client’s name separately. This mechanism complicates tracking who actually sent or received each amount.
Why the mechanism exists
This model was used by fintechs or payment institutions that wanted to automate the operation, reduce costs, or offer services in a more agile manner, often supported by Banking as a Service ( BaaS).
However, this way of operating also generated high risks: by not individualizing accounts in the name of each client, it opens the door to layers of opacity, where amounts can circulate without clear identification of the real holder.
The hidden risk behind the large account
When we think about what a pooling account is, we need to see beyond the name: the wound it represents for the system.
Inviability of judicial blocking
One of the serious consequences of this model is that orders for judicial blocking, garnishments, or financial measures become much more difficult to execute. If a pooling account concentrates resources from many clients, the bank or authority only identifies the titular institution — not each user.
This means that, in credit recovery processes or fraud, creditors or authorities may not be able to locate the actual amount belonging to the end client.
Risk of money laundering and asset concealment
Authorities have already identified cases in which criminal organizations used pooling accounts to move funds of illicit origin without clearly identifying the source or final recipient.
This mix of legal and illegal amounts within a single account transforms the pooling account into a risk vector for the financial system and the credibility of fintechs.
The regulatory response
The Central Bank and the Federal Revenue Service of Brazil are tightening the rules for fintechs, payment institutions, and arrangements of financial services that use the pooling account model or do not individualize user accounts.
This means that institutions operating this way will have to review their models, adopt stricter controls, and offer greater transparency.
How it works in practice — the example of the fintech
To understand what a pool account really is, let’s look at a practical example:
A fintech offers payment accounts to its clients.
Instead of opening an account in the name of each client, it maintains a single owner account with the financial institution, in its own name. This is the "pool account".
Each client using the fintech has a "graphical balance" or "virtual account" in the fintech app: for the client, it looks like an individual account.
When the client makes a transfer or receives a payment, the actual transaction is debited or credited to the fintech's pool account — it does not appear individually in the bank statement in the client's name.
This creates the effect: the bank sees that the fintech moved X reais, but does not see that client A moved Y reais — because this subdivision is internal to the fintech.
This mechanism, although practical for scaling, implies a loss of visibility for authorities, banks, and even for the client themselves regarding who is the actual holder of the funds.
What changes with the new rules and why you should care
With the recent rule from the Central Bank addressing, among other things, the use of pooled accounts, understanding what a pooled account is becomes essential for those who offer or use payment account services.
Consequences for fintechs and payment institutions
Institutions that worked with the pooled account model will have to adopt greater transparency and individualization of clients.
The use of “single account for multiple clients” will be closely monitored by the regulator, possibly requiring the segregation of resources, reports, and individual ownership.
This may generate additional costs, contract revisions, the need for changes to technological infrastructure, and reinforced compliance.
Impacts for users and companies
If you are a customer of a fintech, asking “is this account individualized or part of a pooled account?” becomes relevant for your protection.
For companies that receive payments or operate payment accounts, the risk of using a pooled account may mean less traceability — which can affect audits, freezes, or even reputation with partners or authorities.
In the context of using accounts for payments to clients, suppliers, or transfers, operating with individualized accounts conveys credibility, security, and transparency.
How to ensure security: best practices for the wallet account
To ensure that your operation or your relationship with payment institutions is secure, consider these points:
Check if the payment account is individualized in the name of the end customer; that is, if the account holder appears at the bank as being you or your company.
Confirm that the payment institution has solid compliance, following Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations.
Demand transparency regarding account ownership and the flow of funds — this is part of “knowing what a pool account is” and how it can affect your operation.
For fintechs: consider migrating from the pool account model to individualized accounts or implementing strict internal tracking mechanisms.
For user companies: prefer institutions that claim to operate with individual accounts, segregate funds, and provide clear reports.
The future of the model and the advantage of choosing transparency
As the financial system evolves and regulation intensifies, the pool account model tends to lose ground or will be restructured. There is already pressure for each payment account customer to have real and visible ownership.
For institutions and users who anticipate this transition, adopting individualized accounts will be a market differential.
If you manage a company, work with payments, or are assessing fintechs, knowing what a pool account is is not just technical knowledge: it is part of your security strategy, transparency, and competitive future.
Operate in a regulated manner
Understanding what a pooled account is is key to safely navigating the world of digital payments and fintechs. This model represents a risk channel by pooling funds from multiple clients into a single holder and limiting the traceability of operations.
With the tightening of rules by the Central Bank, the trend is clear: individualized accounts, transparent ownership, clear operations. Those who get ahead will not only be protected — they will be ahead.
At Azify, we use individual accounts to ensure that each client is the owner of their own financial path, without mixtures, without opacities.
