Brazil’s securities regulator, the Comissão de Valores Mobiliários (CVM), issued combined fines totaling R$ 3 million on September 29, 2026, against Neo In Construções e Incorporação Ltda. and two individuals for conducting an unregistered public offering and failing to file required financial disclosures. The unanimous decision addressed violations spanning multiple regulatory frameworks and reflects the CVM’s ongoing enforcement against undisclosed investment solicitations in the Brazilian capital markets.
- Neo In Construção fine: R$ 2,000,000
- Anderson Alves de Macedo fine: R$ 1,000,000
- Violations cited: Articles 2 and 4 of CVM Instruction 400; Articles 4 and 43 of CVM Resolution 160
- Case identifier: PAS 19957.005810/2024-67
In the primary case, the CVM’s Board of Directors condemned Neo In Construção e Incorporação Ltda. – Em Recuperação Judicial to pay R$ 2 million for orchestrating a public investment offering without obtaining mandatory CVM registration. Anderson Alves de Macedo, the company’s administrator, was separately fined R$ 1 million for his role in the same infractions. Both defendants face charges under articles 2 and 4 of the prior CVM Instruction 400, as well as articles 4 and 43 of the current CVM Resolution 160. The regulator’s Superintendent of Securities Registration (SRE) initiated the investigation into the unregistered offering.
A second enforcement action addressed failures by Reag Capital Holdings S.A. administrators to file mandatory financial documentation. The CVM fined João Carlos Falbo Mansur, serving as director president, and Rodolfo Turelli, serving as financial director, R$ 170,000 each for failing to prepare complete annual financial statements for the 2024 fiscal year and quarterly information forms (ITR) for the first and second quarters of 2025. These omissions violated Article 176 of Brazilian Corporate Law and Article 31 of CVM Resolution 80. The Superintendent of Corporate Relations (SEP) investigated the disclosure failures.
Both sets of defendants may appeal the CVM’s decisions to the National Financial System’s Appeal Board with suspensive effect, allowing them to seek review of the penalties. The regulator published detailed technical reports and director votes supporting each decision on its official channels.
