Regulatory Alerts2014-10-25
CVM Resolution No. 541 of May 15, 2008
The Brazilian Securities and Exchange Commission (CVM) mandates that open companies, foreign companies sponsoring BDR programs, and shareholders selling in public distributions must identify all direct and indirect controllers down to the natural person level. This requirement applies regardless of the jurisdiction where the parties are incorporated or domiciled, and confidentiality obligations under foreign laws or private agreements do not exempt them from this disclosure duty. The regulation revokes previous resolution 525 and establishes specific compliance timelines for both newly registered and existing companies.
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