The Brazil Securities Commission (CVM) published its Sanctioning Activity Report covering the fourth quarter of 2025 and the full-year enforcement balance, pointing to a sharp increase in precautionary stop orders and a larger pipeline of investigative and sanctioning proceedings. Stop orders rose to 37 in 2025 from 13 in 2024, increasing quarter by quarter (2, 10, 11 and 14). Alert letters increased to 434 from 388, led by the Superintendence of Relations with Companies (SEP) with 126 and the Superintendence of Securities Registration (SRE) with 118; the CVM describes these letters as notifications of irregularities that do not justify opening an administrative inquiry or issuing charges, while stop orders are precautionary measures aimed at preventing or correcting misconduct. As of December 2025, 804 potentially sanctionable administrative proceedings were ongoing across eight technical areas, and the number of investigative proceedings opened rose to 92 from 59; 95 cases resulted in charges and moved into Administrative Sanctioning Proceedings, which will be decided by the CVM Board or may be closed via settlement agreements. The Board approved 42 settlement agreements in 2025 covering 64 proponents with BRL 33.31 million in proposed payments for diffuse damages, including BRL 11.66 million tied to 15 cases approved in the fourth quarter. Referrals to the Public Prosecutor’s Office increased to 95 letters from 70, with 28 sent to state prosecutors and 67 to the federal prosecutor, most often involving suspected unlicensed activity, fraud and fraudulent management.

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