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.

1case from 1 jurisdiction
€41.2mTotal of monetary amounts
€41.2mMedian per case with an amount

Click a bar to drill down one level.

Where?

by authority
  1. Comissão de Valores Mobiliários (CVM) €41.2m 100 % · 1 case

What for?

by action
  1. Fine €41.2m 100 % · 1 case

Who?

by sector

All sectors

  1. Financial services and insurance €41.2m 100 % · 1 case

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q4 20230–
Q1 20240–
Q2 20240–
Q3 20240–
Q4 20241€41.2m
Q1 20250–
Q2 20250–
Q3 20250–
Q4 20250–
Q1 20260–
Q2 20260–
Q3 20260–
Q4 20260–

1 case

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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