CVM Deliberation No. 905 of November 25, 2025

CVM DELIBERATION NO. 905, OF NOVEMBER 25, 2025

Irregular activity in the securities market by persons not authorized by the CVM, under the terms of Article 27-E of Law No. 6,385, of December 7, 1976, and CVM Resolution No. 20, of February 25, 2021.

The INTERIM PRESIDENT OF THE SECURITIES AND EXCHANGE COMMISSION - CVM makes public that the Collegiate Body, in a meeting held on this date, based on Article 9, paragraph 1, items III and IV, of Law No. 6,385, of December 7, 1976, and Article 1 of CVM Resolution No. 47, of August 31, 2021, and considering that:

a. the CVM found evidence indicating that SANTO TRADER TREINAMENTO PROFISSIONAIS LTDA., CNPJ No. 41.557.647/0001-04, and OLIVER AUGUSTO MORENO SPANGHERO, CPF: xxx.736.179-xx, through websites with addresses at https://santotrader.com/ and https://santotrader.me/, the YouTube channel "https://www.youtube.com/@SANTOTRADER" and the Instagram page "https://www.instagram.com/oliversantotrader/", are publicly offering securities analysis services in Brazil;

b. the activity of providing securities analysis services requires prior authorization from the CVM, as provided in Article 27 of Law No. 6,385, of December 7, 1976, and CVM Resolution No. 20, of February 25, 2021; and

c. the exercise of the activity of securities analyst without observing the legal or regulatory requirements characterizes, in theory, the crime provided for in Article 27-E of Law No. 6,385, of 1976,

DELIBERATED:

I - to alert participants in the securities market and the general public about the fact that:

a. SANTO TRADER TREINAMENTO PROFISSIONAIS LTDA. and OLIVER AUGUSTO MORENO SPANGHERO, because they do not meet the requirements set forth in CVM regulations, cannot provide securities analysis services;

II - to order SANTO TRADER TREINAMENTO PROFISSIONAIS LTDA. and OLIVER AUGUSTO MORENO SPANGHERO to immediately suspend the broadcasting in Brazil of any offer of securities analysis services, alerting that non-observance of this determination will subject them to the imposition of a daily coercive fine, in the amount of R$ 50,000.00 (fifty thousand reais), without prejudice to liability for infractions already committed before the publication of this Deliberation, with the imposition of the appropriate penalty, under the terms of Article 11 of Law No. 6,385, of 1976, after the regular administrative sanctioning process; and

III - that this Deliberation enters into force on the date of its publication.

Signed electronically by OTTO EDUARDO FONSECA DE ALBUQUERQUE LOBO Interim President