Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific and Middle East: 1,929 cases from 40 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

4cases from 1 jurisdiction
€41.9mTotal of monetary amounts
€310,597Median per case with an amount

Click a bar to drill down one level.

Where?

by authority
  1. Comissão de Valores Mobiliários (CVM) €41.4m 99 % · 3 cases
  2. Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS) €432,774 1 % · 1 case

What for?

by topic
  1. Market abuse and insider dealing €41.2m 98 % · 1 case
  2. Organisational requirements €472,487 1 % · 2 cases
  3. Disclosure and reporting obligations €188,419 0 % · 1 case

Who?

by sector

All sectors

  1. Financial services and insurance €41.9m 100 % · 4 cases

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q4 20230–
Q1 20240–
Q2 20240–
Q3 20240–
Q4 20241€41.2m
Q1 20251€188,419
Q2 20251€39,713
Q3 20250–
Q4 20250–
Q1 20260–
Q2 20260–
Q3 20261€432,774
Q4 20260–

4 cases

15 Oct 2024 Florim Consultoria Ltda. (ehem. Silverado Gestão e Investimentos), Santander Caceis Brasil DTVM S.A., Gradual CCTVM S.A. – Massa Falida u. a. (5 Unternehmen)CVM fines Florim, Santander Caceis, BNY Mellon and Deutsche Bank in Silverado FIDC case BrazilMarket abuse and insider dealing €41.2m

The Comissão de Valores Mobiliários (CVM, securities regulator) ordered Florim Consultoria Ltda. (formerly Silverado Gestão e Investimentos Ltda.) to pay BRL 244,979,397.58 for fraudulent transactions in managing three receivables funds (FIDC). For deficient controls as administrators or custodians of the funds, Santander Caceis Brasil DTVM S.A. received BRL 2,720,000.00, Gradual CCTVM S.A. – Massa Falida BRL 1,700,000.00, BNY Mellon Serviços Financeiros DTVM S.A. BRL 1,200,000.00 and Deutsche Bank S.A. – Banco Alemão BRL 500,000.00, totalling BRL 251,099,397.58 against companies. BNY Mellon, Gradual, Santander Caceis and Deutsche Bank were acquitted of certain charges.

What organisations can take from it

Administrators and custodians of receivables funds must actively check evidence of receivables and the manager's account access – otherwise they are liable alongside the manager.

Relevance to training and awareness

Control duties of fund administrators and custodians

Authority / court
Comissão de Valores Mobiliários (CVM)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Instrução CVM 08/1979, Ziff. I i. V. m. II c; Instrução CVM 356/2001, Art. 8 § 3 I, Art. 38 III und IV, Art. 39 II und III i. V. m. § 4
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
16 Oct 2024

Original amount 251,099,397.58 BRL, converted at the ECB reference rate of 15 Oct 2024.

Checked against the official source on 3 Oct 2026 · Direct link

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12 Aug 2026 Lebes Financeira S.A. – Sociedade de Crédito, Financiamento e InvestimentoLebes Financeira: BRL 2.58m over lending to a related party above the limit BrazilOrganisational requirements €432,774

The BCB (central bank) sanctions committee COPAS imposed a fine of BRL 2,576,000.00 on Lebes Financeira S.A. – Sociedade de Crédito, Financiamento e Investimento because from January 2022 to March 2023 it engaged in prohibited credit transactions with a related company: its banking correspondent retained collected loan instalments, and the arrears reached BRL 147m at the end of November 2022, or 207.66% of adjusted equity against a limit of 10%. In addition there was a BRL 20m loan routed through a third company. The decision is not final.

What organisations can take from it

If an affiliated distribution partner retains customer money, this can quickly become a prohibited loan to a related party.

Authority / court
Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Lei 13.506/2017, Art. 3 II; Lei 4.595/1964, Art. 34 § 3 V d und § 4 I; Resolução CMN 4.693/2018, Arts. 5, 6 und 7 II
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.

Original amount 2,576,000 BRL, converted at the ECB reference rate of 12 Aug 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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8 Apr 2025 Regen Serviços Fiduciários Ltda.Regen Serviços Fiduciários: BRL 255,000 CVM fine over incorrect liquidity data BrazilOrganisational requirements €39,713

The CVM ordered Regen Serviços Fiduciários Ltda. to pay a fine of BRL 255,000.00 because its internal controls failed and it repeatedly submitted incorrect information to the authority on the liquidity of the investment funds it administered (Art. 19 Instrução CVM 558 until 30 June 2021, thereafter Art. 22 Resolução CVM 21). The company had not submitted a defence; an appeal with suspensive effect to the CRSFN was available against the decision.

What organisations can take from it

Regulatory reports on fund liquidity need their own plausibility checks; repeated errors count as an organisational failure.

Authority / court
Comissão de Valores Mobiliários (CVM)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Instrução CVM 558/2015, Art. 19; Resolução CVM 21/2021, Art. 22
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
8 Apr 2025

Original amount 255,000 BRL, converted at the ECB reference rate of 8 Apr 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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11 Mar 2025 Intra DTVM Ltda.Intra DTVM: CVM fine of BRL 1.2m for missing fund filings BrazilDisclosure and reporting obligations €188,419

The board of the Comissão de Valores Mobiliários (CVM, Brazilian Securities and Exchange Commission) fined the fund administrator Intra DTVM Ltda. BRL 1,200,000.00 for filing mandatory periodic information on the investment funds it administered late or not at all (Art. 59 Instrução CVM 555). According to the charges, 121 mandatory documents for 12 of the 19 funds it administered were missing at the end of the 2020 financial year; the company was acquitted of the charge of breaching its duty of diligence on a tied vote, since in that event the view more favourable to the accused prevails. An appeal against the decision is pending before the Conselho de Recursos do Sistema Financeiro Nacional (CRSFN, financial system appeals board). The decision is not final.

What organisations can take from it

Fund administrators need a robust deadline and control system so that mandatory information for every fund reaches the regulator on time.

Relevance to training and awareness

Timely mandatory filings with the regulator

Authority / court
Comissão de Valores Mobiliários (CVM)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Instrução CVM nº 555/2014, Art. 59
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
18 Mar 2025

Original amount 1,200,000 BRL, converted at the ECB reference rate of 11 Mar 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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