Joint Circular CVM/SIN/SMI No. 1/2025

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL
Rua Sete de Setembro, 111/2-5th and 23-34th Floors – Center – Rio de Janeiro - RJ – ZIP: 20050-901 – Brazil Tel.: (21) 3554-8686 - www.cvm.gov.br Joint Circular No. 1/2025/CVM/SIN/SMI Rio de Janeiro, February 18, 2025

To the Directors of Intermediaries referred to in Article 5, Item I, of CVM Resolution No. 35/21.

Subject: Monitoring of operations and communication to the CVM provided for in Items IV and IX of Article 33 of CVM Resolution No. 35/2021 - Circular No. 1/2024/CVM/SMI.

Dear Sirs,

1. In complement to the guidelines issued in Circular No. 1/2024/CVM/SMI, of March 28, 2024, the Department of Market and Intermediary Relations (SMI) and the Department of Institutional Investor Supervision (SIN) reinforce that, in the monitoring of operations executed by intermediaries, when indications of irregular management of securities portfolios are detected, the communication of facts must be addressed to SIN through the electronic protocol (https://www.gov.br/pt-br/servicos/protocolar-documentos-junto-a-cvm). If other irregularities are identified in addition to indications of the management of third-party resources, this communication must be forwarded to both areas.

2. It is understood that irregular management comprises the application of third-party resources in securities by a person without prior accreditation with this CVM. This accreditation can be verified through a query to the general registry at https://sistemas.cvm.gov.br/

3. Among the minimum controls that must be implemented to identify the mentioned irregularity, the following stand out: verification of unaccredited third parties acting as proxies for investors, not only, but mainly, with operations carried out in the spot and options markets; different clients with coordinated operations from the same source IP; legal entities with a corporate name and/or trade name that mentions the word “investments”; monitored persons’ social media that mention the offer of investment services; unaccredited legal entities with proprietary desks; and application in one’s own name of resources incompatible with one’s own financial capacity (both for individuals and legal entities).

4. Communications must be sent with the largest number of supporting documents and information possible, including, where applicable, contact data of the monitored persons (name, CPF or CNPJ, electronic address, social media links, phones, etc.).

5. Finally, it is worth noting that this guidance does not supersede the need for implementation of additional controls and routines that the participant deems necessary.

Sincerely,

Digitally signed by
MARCO ANTONIO VELLOSO DE SOUSA

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL
Rua Sete de Setembro, 111/2-5th and 23-34th Floors – Center – Rio de Janeiro - RJ – ZIP: 20050-901 – Brazil Tel.: (21) 3554-8686 - www.cvm.gov.br Head of the Department of Institutional Investor Supervision Digitally signed by ANDRÉ FRANCISCO DE ALENCAR PASSARO Head of the Department of Market and Intermediary Relations