The Brazil Securities Commission has ruled on two settlement proposals in administrative sanctioning proceedings, rejecting an offer from Fábio Aylton Casal de Rey, chair of the board of Blue Tech Solutions EQI S.A., and accepting a proposal from Rafael Nanni Trapé, an equity fund manager. In Trapé’s case, the agreed terms include full reimbursement of affected fund unitholders for the undue loss they individually bore, adjusted by the IPCA from 7 May 2025 until payment, a BRL 237,020.70 payment to the CVM also adjusted by the IPCA, and a 12 month temporary suspension from portfolio management activity under CVM Resolution 21. In the Blue Tech case, the CVM followed its settlement committee in finding the proposal inappropriate in light of the alleged seriousness of the conduct, Casal de Rey’s history in activities involving the company, the limited procedural economy because three other defendants did not submit proposals, and the fact that the board had already rejected a similar proposal from him on 18 February 2025 in a case of comparable alleged gravity. The underlying proceeding concerns alleged failures to exercise the diligence required of a listed company director by not supervising the investor relations officer’s maintenance of registered share ownership and transfer records and by not ensuring implementation of changes requested by the company’s independent auditors for the 2020 financial statements. Trapé’s proceeding was opened to investigate alleged fraudulent securities market transactions carried out between 4 April 2025 and 7 May 2025 in breach of CVM Resolution 62. Under the accepted settlement, reimbursement must be made within 30 days of execution of the agreement. Trapé must also provide the CVM with a detailed spreadsheet identifying the affected unitholders and their respective fund interests, with the source of the information confirmed by the fiduciary administrator, and submit documentation proving the compensation payments.