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The Board of the Brazilian Securities Commission (CVM) examined at a meeting of 14/12/2021 Declaration of Commitment proposals of the following process s Administrative s Sanctioning s (PAS):
- PA S SEI 19957.002344/2021-15 : Vinícius Loureiro Ibraim .
- PA S SEI 19957.005174/2019-14 : Alex da Silva Jorge, Carlos Maurício da Silva Maduro, Cristiane d e Souza Veiga, Gustavo Adolfo Magalhães Machado, João Pedro Cerva Themudo and Luiz Felipe Ribeiro Barbosa .
3 . PA S SEI 19957.007433/2020-77 : Exponential Solutions Training and Administration Ltda., Skoben Capital Participações Ltda., Maico Buge Kautsky and Frederico Almeida Saleme do Valle .
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- Vinícius Loureiro Ibraim presented a proposal for a term of commitment to close the PAS SEI 19957.002344/2021-15 .
The Specialized Federal Attorney at the Autarchy (PFE-CVM) concluded that there was a legal impediment to the execution of the agreement , in view of the damages pointed out by the technical area .
In analyzing the case, the Committee Commitment Term (CEC) did not find it convenient or appropriate to enter into the agreement, considering that the proposal does not address the loss indemnity provision at the individual level in theory caused, as well as diffuse damage
The Collegiate followed the CTC and rejected the agreement with Vinícius Loureiro Ibraim .
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The PAS SEI 19957.002344 / 2021-15 was established by the Superintendency of Investor Institutional Supervision (SIN) to investigate alleged exercise of management activities of securities portfolios without registration with the CVM ( offense, in theory, the s art s . 23 , of Law 6.385/76, and 2, of CVM Resolution 21) .
Access the opinion of the Term of Commitment Committee.
- Alex da Silva Jorge, Carlos Maurício da Silva Maduro, Cristiane de Souza Veiga, Gu stavo Adolfo Magalhães Machado and João Pedro Cerva Themudo feature coffee plow proposed joint commitment term , and Luiz Felipe Ribeiro Barbosa , individual , for terminating r the PAS SEI 19957.005174/2019-14 .
The Specialized Federal Attorney at the Autarchy (PFE-CVM) concluded that there was no legal impediment to the execution of the agreement.
Upon analyzing the case, the Term of Commitment Committee (CTC) understood that it would not be convenient and opportune to accept the proposal , since, despite the negotiation attempts, the proposed values were very far from what would be the adequate and sufficient counterpart to discourage similar practices .
The Board followed the CTC and rejected the agreement with Alex da Silva Jorge, Carlos Maurício da Silva Maduro, Cristiane de Souza Veiga, Gu stavo Adolfo Magalhães Machado, João Pedro Cerva Themudo and Luiz Felipe Ribeiro Barbosa .
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The PAS SEI 19957.005174 / 2019-14 was introduced by Superintendent sanctioning processes (SPS) to determine supposed p not equal rática, the mode front running , the prestigious shape in section II, “d”, of CVM 8 (infraction in thesis, to item I of the same Instruction ).
Access the opinion of the Term of Commitment Committee .
3 . Exponential Solutions Training and Administration Ltda. (as offeror) , Skoben Capital Participações Ltda. (as offeror) , Maico Buge Kautsky (as a partner and responsible for Exponential Solutions) and Frederico Almeida Saleme Valle (as a partner and responsible for Skobe n Participações ) presented p PROPOSAL joint commitment term for terminating r o PAS SEI 19957.007433/2020-77 .
The Specialized Federal Attorney at the Autarchy (PFE-CVM) concluded that there was a legal impediment to the execution of the agreement, in view of the non-interruption of the irregular offer, even after a subpoena from the Autarchy.
After analyzing the case, the Term of Commitment Committee (CTC ) considered it neither convenient nor opportune to enter into the agreement, considering, among other factors, the gravity, in theory, of the case.
The Collegiate accompanied the CTC and rejected the agreement with Soluções Exponenciales Training and Administration Ltd., Skoben Capital Participações Ltd., Maico Buge Kautsky and Frederico Almeida Saleme do Valle.
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The PAS SEI 19957.007433 / 2020-77 was established by the Superintendency of Securities Registration Securities (SRE) to investigate alleged r MPLEMENTATION public offering of securities without due registration (infraction, in theory, the s art s . 19 of Law 6,385 / 76 and 2, the CVM 400) and without remission (infringement, in principle, the s article s . 19 I, paragraph 5 , of Law No. 6,385 / 76, and 4 of CVM 400)
Access the opinion of the Term of Commitment Committee .