Who was sanctioned, and for what?

The Controladoria-Geral da União (CGU, Office of the Comptroller General) fined Bulls Holding Investments Company S.A. BRL 387,431,733.02 and RS Investimentos S/A BRL 121,380,000.00 (BRL 508,811,733.02 in total) and ordered extraordinary publication of the decision for each. According to the final report, the companies had submitted to the insurance supervisor SUSEP bids to take over the pension association APLUB, which was under special intervention, backed by inadequate and in part apparently forged documents, thereby interfering with SUSEP's supervisory activity; RS Investimentos was additionally sanctioned for supporting Bulls Holding's acts. The amount and the facts have not been confirmed against the primary source.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 II und V, Art. 6 I und II, Art. 14

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Liability of senior managers

Measures against individuals are not set out here.

Published

2 Oct 2025

Original amount 508,811,733.02 BRL, converted at the ECB reference rate of 30 Sep 2025.

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

The Comitê de Decisão de Processo Administrativo Sancionador (COPAS, sanctions decision committee) of the Banco Central do Brasil (Brazilian central bank) fined Banco Genial S.A. a total of BRL 21,560,000.00: BRL 4,200,000.00 for inadequate anti-money laundering policies, procedures and controls, BRL 8,920,000.00 for failing to verify the credentials of foreign exchange clients and BRL 8,440,000.00 for failing to file suspicious activity reports with the financial intelligence unit Coaf in the proper form and on time. According to the case documents, the reporting charge concerned 1,364 foreign exchange transactions for the acquisition of virtual assets with five clients between November 2020 and October 2021, totalling USD 744,341,982.45.

Authority / court

Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)

Area of law

Money laundering and terrorist financing · Customer due diligence

Legal basis

Lei nº 9.613/1998, Art. 10 III, Art. 11 und 12; Lei nº 13.506/2017; Circular BCB nº 3.978/2020; Resolução CMN nº 3.568/2008

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Liability of senior managers

Measures against individuals are not set out here.

Original amount 21,560,000 BRL, converted at the ECB reference rate of 12 Aug 2026.

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

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.

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

IRB-Brasil Resseguros S.A. concluded a Termo de Compromisso (settlement in sanction proceedings) with the CGU and allegedly pays a fine of BRL 6,317,473.41 because the company had hindered the investigative and supervisory activity of the insurance supervisor SUSEP (Art. 5 V Lei 12.846/2013). The fine equals the statutory minimum of 0.1% of gross revenue (BRL 6,509,921.81) less BRL 192,448.40 already paid in SUSEP proceedings over inconsistent reporting. Extraordinary publication was waived, and the proceedings are thereby closed.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei 12.846/2013, Art. 5 V, Art. 6 I; Decreto 11.129/2022, Art. 25 § 2; Portaria Normativa CGU 155/2024

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Repeat case

no

Mitigating circumstances

Credit was given for a compliance programme (3.6%), the absence of proof of advantage or damage (1%) and settlement-related reductions for cooperation and admission; fines already paid to SUSEP were deducted.

Published

3 Jul 2026

Original amount 6,317,473.41 BRL, converted at the ECB reference rate of 2 Jul 2026.

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

The sanctions committee COPAS of the Banco Central do Brasil (central bank) imposed fines totalling BRL 16,280,000.00 on Banco Topázio S.A.: BRL 4,560,000.00 because its monitoring system contained no rules for foreign exchange transactions to buy and sell virtual assets, BRL 3,280,000.00 because suspicious transactions were not reported, or reported late, to the financial intelligence unit Coaf (including BRL 3.05bn from one client), and BRL 8,440,000.00 because the bank had not verified the qualification of foreign exchange clients. In addition, for two years it may not carry out over-the-counter foreign exchange transactions for virtual assets in which the client acts as an unauthorised intermediary for third parties. The decision is not final.

Authority / court

Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)

Area of law

Money laundering and terrorist financing · Suspicious activity reports

Legal basis

Lei 9.613/1998, Art. 10 III, Art. 11 II, Art. 12 II und § 2 II und IV; Circular BCB 3.978/2020, Arts. 38, 39 und 48; Lei 13.506/2017, Art. 3 XVII, Art. 5 II und IV

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 16,280,000 BRL, converted at the ECB reference rate of 11 May 2026.

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

On 22 October 2025 the CADE Tribunal approved, in a single block, five cease-and-desist settlements (Termos de Compromisso de Cessação, TCC) with banks and allegedly set the following pecuniary contributions: BofA Securities Inc. 33,010,207.04 BRL, Nomura International plc 32,145,917.76 BRL, Standard Chartered Bank 11,544,947.78 BRL, Credit Suisse AG 1,582,051.57 BRL and MUFG Bank 714,782.33 BRL, together 78,997,906.48 BRL. The session minutes do not state the subject of the proceedings; all five banks are, however, among the parties whose conviction the General Superintendence had recommended in April 2025 in the proceedings on the offshore foreign-exchange cartel (according to CADE, collusion on the prices of FX transactions, exchange of sensitive information and disadvantaging other market participants such as brokers). The amount and the facts have not been confirmed against the primary source.

Authority / court

Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo

Area of law

Competition law · Cartels and collusion

Legal basis

Lei nº 12.529/2011 (Termo de Compromisso de Cessação)

Action

Other

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Liability of senior managers

Measures against individuals are not set out here.

Published

30 Oct 2025

Original amount 78,997,906.48 BRL, converted at the ECB reference rate of 22 Oct 2025.

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

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.

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

Qualicorp Consultoria e Corretora de Seguros S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that it had paid an economic advantage to a public official whose action or omission was in the company's interest. It allegedly pays BRL 44,485,434.29 as a fine plus disgorgement: BRL 27,803,396.43 as disgorgement of the advantage obtained and a fine of BRL 16,682,037.86 under Lei 12.846/2013 (40% reduction), both indexed to IPCA up to December 2024. The agreement extends to other companies of the Qualicorp group. The amount and the facts have not been confirmed against the primary source.

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Lei 12.846/2013, Art. 6 I, Arts. 16 und 17, Art. 19 I; Lei 8.429/1992; Decreto 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Credit was given for returning the advantage (1%), cooperation (1.5%) and voluntary admission (2%); no compliance programme was taken into account. The fine equals the statutory minimum of the advantage obtained, then reduced by 40%.

Liability of senior managers

Tolerance or knowledge by senior management was applied as an aggravating factor at the maximum rate of 3%.

Original amount 44,485,434.29 BRL, converted at the ECB reference rate of 17 Mar 2025.

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

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.

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

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.

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