Central Bank Administrative Sanctioning Proceedings

The Central Bank's administrative sanctioning proceeding has its own jurisdiction and rules, relating to the institutions and activities under its supervision. Analyzing the allegation requires identifying the conduct, the period, the regulatory duty involved and the participation of each person or institution. The existence of an operational irregularity does not excuse the examination of the elements necessary to establish liability. The proceeding is distinct from the CVM's sanctioning proceeding, even when the facts involve participants from both markets.

Advisory work includes responding to notices, presenting a defense, analyzing evidence and following up on decisions and appeals. Instruments such as a commitment term and an administrative agreement in supervisory proceedings may also be evaluated, each with its own requirements and effects. The history of remediation of deficiencies and governance records must be examined without presuming that subsequent measures eliminate prior violations. The strategy also takes into account the continuity of regulatory obligations while the proceeding is pending.

Our work

• Defenses and submissions before the Central Bank
• Analysis of liabilities and control documentation
• Evaluation of consensual instruments and appeals

Does the Central Bank's sanctioning proceeding follow the same rite as the CVM's?

No. The authorities have their own jurisdiction and procedural rules. The defense must observe the regime of the responsible authority and the violations actually alleged.

Editorial review: 2026-10-26