CVM Deliberation No. 903 of October 28, 2025

CVM DELIBERATION NO. 903, OF OCTOBER 28, 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. 21, 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 KADRYX FINANCIAL SERVICES LTDA., CNPJ No. 61.601.016/0001-44, through the website https://kadryxpartnersinvestments.com/ and groups in messaging applications, has been publicly offering portfolio management services for securities in Brazil;

b. the activity of providing portfolio management services for securities requires prior authorization from the CVM, as provided in Article 23 of Law No. 6,385, of December 7, 1976, and CVM Resolution No. 21, of February 25, 2021; and

c. the exercise of the activity of portfolio management for securities without observing legal or regulatory requirements constitutes, 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 that KADRYX FINANCIAL SERVICES LTDA., due to not meeting the requirements established in CVM regulations, cannot provide portfolio management services for securities;

II - to order KADRYX FINANCIAL SERVICES LTDA. to immediately suspend the dissemination in Brazil of any offer of portfolio management services for securities, alerting that failure to comply with this determination will subject them to a daily coercive fine in the amount of R$ 100,000.00 (one hundred thousand reais), under the terms of Article 1 of Annex B to CVM Resolution No. 47, of August 31, 2021, without prejudice to liability for infractions already committed prior to the publication of this Deliberation, with the imposition of the applicable 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