Brazil Securities Commission publishes Q2 2025 enforcement activity report as warning letters more than double and stop orders rise to 10

The Brazil Securities Commission (CVM) published its Enforcement Activity Report for the second quarter of 2025, reporting a marked increase in early-stage supervisory interventions, with warning letters more than doubling from the prior quarter and a higher number of stop orders. Between April and June 2025, CVM issued 115 warning letters versus 46 in the first quarter, across seven technical areas, with the Securities Registration Superintendence issuing the most (38). Stop orders rose to 10 from two in January to March. As of June, 860 administrative proceedings with sanctioning potential were ongoing across eight technical areas. During the quarter, 26 investigative administrative procedures were opened, resulting in 21 ordinary statements of charges, three simplified statements of charges, and two administrative inquiries; 20 administrative proceedings concluded with accusations and moved into Administrative Sanctioning Proceedings to be judged by CVM’s Board or potentially closed via a settlement agreement. The Board approved 11 settlement agreements totaling BRL 9.44 million and, in adjudications, imposed BRL 2,508,919.60 in fines across 10 sanctioning proceedings, sanctioning 12 individuals (10 fines, one warning, one ban) and acquitting four. CVM also sent 23 referrals to public prosecutors (seven state and 16 federal) covering suspected crimes including unauthorized activity, pyramid schemes, fraudulent management of a financial institution, and fraud.