2025-11-04

CVM Resolution No. 904 of November 4, 2025

The Brazilian Securities and Exchange Commission (CVM) issued Resolution No. 904 to address the irregular public offering of securities by Marcus Vinicius Lopes Melo and Sigma Solucoes Digitais e Treinamentos Ltda. The regulator determined that the entities offered cryptoasset-linked investment contracts without the required registration, violating the Securities Law. Consequently, the CVM ordered the immediate cessation of these activities and imposed a daily fine of R$ 100,000 for non-compliance.

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CVM RESOLUTION NO. 904, OF NOVEMBER 4, 2025 Irregular offering of securities without the registration provided for in Law No. 6,385, of December 7, 1976.

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 art. 9, § 1, items III and IV, combined with art. 16, both of Law No. 6,385, of December 7, 1976, and considering that:

a) the CVM found that Mr. MARCUS VINICIUS LOPES MELO, CPF: *.493.808-, and SIGMA DIGITAL SOLUTIONS AND TRAINING LTD, CNPJ: 37.980.396/0001-90, have been offering, through the website https://crypto.sigmainfinity.com.br/, an investment opportunity whose remuneration would be linked to leasing, arbitrage, and management operations of cryptoassets carried out by the company itself, appealing to the Brazilian public to enter into contracts that, in the manner in which they are being offered, fall under the legal concept of securities;

b) according to item IX of art. 2 of Law No. 6,385, of December 7, 1976, titles or collective investment contracts that generate rights of participation, partnership, or remuneration, including resulting from the provision of services, whose earnings derive from the effort of the entrepreneur or third parties, can only be publicly offered through registration of the offering or its waiver with the CVM;

c) the public offering of securities, the dissemination of which has been widely carried out through the aforementioned website and social networks, was not submitted to registration nor to a waiver of registration before the CVM, which constitutes a violation of art. 19 of Law No. 6,385, of December 7, 1976; and

d) the offering of securities to the public residing in Brazil, without prior authorization from the CVM, confers powers to this Autarchy to determine the prohibition of such practice, in the form of art. 9, § 1, item IV, combined with art. 16, both of Law No. 6,385, of December 7, 1976, without prejudice to the applicable administrative sanctions, and constitutes, in theory, the crime provided for in art. 27-E of the same law.

DELIBERATED:

I – to alert participants in the securities market and the general public that the aforementioned participants are not qualified to publicly offer titles or collective investment contracts, whose remuneration is linked to leasing, arbitrage, or management operations of cryptoassets (https://crypto.sigmainfinity.com.br/), as defined in item IX of art. 2 of Law No. 6,385, of December 7, 1976, given that it is a public offering without registration or waiver thereof with the CVM;

II – to order the aforementioned participants, and all their partners, managers, administrators, and agents, to immediately cease activities related to the offering of securities to the public residing in Brazil, in accordance with art. 16 of Law No. 6,385, of December 7, 1976, alerting that non-compliance with this determination will result in a daily coercive fine in the amount of R$ 100,000.00 (one hundred thousand reais), without prejudice to liability for infractions already committed, with the imposition of the applicable penalty, in accordance with art. 11 of Law No. 6,385, of December 7, 1976; and

III – that this Resolution enters into force on the date of its publication.

Signed electronically by OTTO EDUARDO FONSECA DE ALBUQUERQUE LOBO Interim President