The Brazil Securities Commission (CVM) board reviewed proposed commitment terms (Termo de Compromisso) in one administrative proceeding and two sanctioning proceedings, rejecting the proposal submitted by Silvio Tini de Araújo and partially accepting a global proposal submitted by Sebastian Kunert. In the Alpargatas case, the proposal was filed before a sanctioning proceeding was opened and related to alleged irregularities involving trading in Alpargatas S.A. shares during a prohibited period (possible breach of Article 14 of CVM Resolution 44). While the CVM’s Office of the Attorney General found no legal impediment to an agreement, the Commitment Term Committee recommended rejection based on the alleged seriousness of the matter, the proponent’s history, and the circumstances of the conduct, and the board followed that recommendation. For Kunert, acting as an investor issuing options orders for his own account and on behalf of others, the committee split the global proposal across two cases: it recommended acceptance in PAS 19957.005754/2024-61 (alleged fraudulent operations in the securities market involving options between 15/12/2021 and 22/9/2023) and rejection in PAS 19957.015425/2024-28 (alleged unregistered portfolio management activity over the same period). The board accepted the settlement in PAS 19957.005754/2024-61, requiring reimbursements to five investors of BRL 377, BRL 11,932, BRL 73,023, BRL 9,317 and BRL 4,793, plus a payment to the CVM of BRL 217,920 for diffuse market damages, all updated by the IPCA inflation index from 22/9/2023 until payment, and rejected the settlement in PAS 19957.015425/2024-28 after the proponent did not agree to the committee’s counterproposal.