The Brazil Securities Commission (CVM) has decided three administrative sanctioning proceedings, imposing fines on an audit firm, two individuals accused of creating artificial market conditions through trades with pre-arranged results, and an asset manager and its responsible director over alleged failures in diligence in managing credit assets held by a fixed-income fund. In the fund-related case, the CVM Board unanimously acquitted the respondents on a separate allegation of breaching the fund’s investment policy. Guimarães & Associados Auditores Independentes S/S was fined BRL 25,000 for alleged non-compliance with continuing professional education requirements (NBC PG 12 (R3)) and related obligations under CVM Instruction 308 and CVM Resolution 23. Celso Luiz Martins Vieira and Paulo José Martins Vieira were each fined BRL 402,500 for allegedly creating artificial conditions of supply, demand and price by executing transactions with pre-adjusted outcomes, in breach of CVM Resolution 62. In a case concerning Interativa Investimentos Ltda. as manager of the BRA1 Fixed Income Investment Fund and Jorge Farah Elias as the director responsible for portfolio management, the Board (by majority) rejected a statute of limitations defence for acquisitions of CCBs before 2015 and imposed fines of BRL 400,000 and BRL 200,000, respectively, for alleged lack of diligence in the selection, acquisition and monitoring of credit assets, while unanimously dismissing the allegation of breach of the fund’s investment policy under CVM Instruction 555. In each case where sanctions were imposed, the sanctioned parties may appeal with suspensive effect to the National Financial System Appeals Council.