Brazil has become a kind of global factory for regulated investment funds. In 2014, it took the first position in terms of the number of these structures and, since then, it has taken off from other countries, according to figures aggregated by IIFA, the acronym in English for International Association of Investment Funds.
The entity brings together information from 44 jurisdictions, including Brazil, represented by Anbima (Brazilian Association of Financial and Capital Market Entities).
During the period, the number of regulated funds in Brazil in the IIFA survey went from 14.4 thousand to 32.3 thousand at the end of the first quarter of this year — almost double that of second place, South Korea, which at the end of March had 17.3 thousand.
Three types of funds account for 47.2% of this Brazilian boom, according to data from Anbima: multimarkets, FIPs (participation investment funds) and, above all, Fidcs (credit rights investment funds). These are vehicles that can give rise to structures that are not transparent.
The IIFA international comparison does not consider all funds. The data brings together funds that are open-ended, have redeemable shares and have limits designed to protect the shareholder, such as restrictions on diversification or leverage for investing the resource. It is the product with an exit port and protection mechanisms against risks. In short: funds regulated for investor protection.
The classification does not include, for example, private equity funds or hedge funds in the USA, which totaled 58,891 funds at the end of 2025, according to the SEC (Securities and Exchange Commission). They have a restricted offer, aimed at qualified investors, and regulation falls on the manager, not the fund.
Equivalent Brazilian funds, such as FIP, are accounted for by IIFA. Even though they are not open, they are regulated by the CVM (Securities Commission) and have some application limits.
The CVM, however, was not prepared to increase investor protection during this boom. What was seen during the period was its weakening, accompanied by an increasing number of criminal investigations, which investigate the use of funds for fraud, hiding assets, embezzlement and money laundering, even by organized crime.
Of the trio of funds that grew the most, multimarket is the most flexible, with great allocation freedom. Invests in different types of assets, mixing fixed income, shares, credit, derivatives and shares of other funds, using different strategies, including leverage.
The FIP buys shares in any type of company, listed or not. In the extreme worst example, it is possible that the FIP is even in a shell company without this being clear. Used in a chain, it can make it more difficult to discover who the real investor in a company is.
As the name suggests, Fidc invests in "credit rights", that is, purchasing in cash, at a discount, debt securities that will be paid in the future, such as bills, credit card invoices, checks, store booklets, rental contracts, credit for companies in difficulty. As the fund often mixes securities from numerous creditors, it is difficult for outside investors to see the quality of each security, who the debtor is or the history of that credit.
From 2014 to 2018, the number of Fidcs doubled; then, it quadrupled, accumulating an increase of 810% until March of this year. According to Anbima, 3,757 were created, more than in fixed income (3,593), pensions (3,318) and shares (2,085). In the 12 months up to July, it was almost two a day. The assets are worth R$960 billion, according to the CVM.
With the growth of this industry, part of the credit supply in the country, traditionally made by banks, was replaced by Fidcs, as financial institutions became more selective in releasing loans with the increase in default rates. Among the largest creditors in the judicial recovery of Casas Bahia, for example, is Fidc IBCB-AF01, with more than R$1 billion to be received and used to finance the retailer.
Last week, the Central Bank's Financial Stability Committee highlighted that the use of funds in multiple chains is making it difficult to assess the risk assumed by economic agents in this credit market, especially with the increasing use of Fidc structures.
“The expansion of these funds to finance companies is a cause for concern,” says economist Marcos Lisboa.
Those who work to combat the criminal use of funds remember that almost everything can be packaged in these more flexible structures — for better or for worse. "Although completely legal, funds with several layers, protected by secrecy, make it difficult to identify the owner of the money", explains PF (Federal Police) delegate Alexandre Custódio Neto.
Launched by the PF on August 6, Operation Heritage investigates embezzlement and money laundering in an alleged diversion of R$308 million in an agreement between Oi and the government of Mato Grosso, with two Fidcs. The targets deny wrongdoing.
Operation Hidden Carbon, from August 2025, evaluates 40 funds, including FIPs, multimarkets, real estate agencies and Fidcs, suspected of concealing assets and laundering money from people linked to the PCC (First Command of the Capital).
Some of the funds investigated by Carbono Oculto were also part of the Banco Master fraud scheme, run by Daniel Vorcaro, according to a complaint from the Central Bank. They were managed by Reag, a manager liquidated by the BC.
"I have nothing against the fund itself. It is a legitimate option for those who want to invest, but some structures are at the service of crime. We came across funds not only in Carbono Oculto, but in all the recent operations against the PCC — Fim da Linha, Hydra and Última Parada", prosecutor Lincoln Gakiya, from the Public Ministry of the State of São Paulo, member of the Special Action Group to Combat Organized Crime, told Folha.
The risk of funds gained new contours with the US declaring PCC and Red Command as terrorist organizations and providing for punishments for anyone who has an economic relationship with these factions.
At the 6th edition of the Integrity Conference, of the International Chamber of Commerce Brazil, which discussed how companies should protect themselves from the risks associated with organized crime, the director of governance and compliance at Petrobras, Ricardo Wagner de Araújo, spoke to the audience about a checklist that included the following question when doing business: "Does it have a basis?".
Araújo told Folha that the state-owned company scrutinizes links with funds before hiring. “If we are investing or forming a partnership, and the company is made up of some fund, we need to know it in detail,” he said.
"It is important to know who the beneficiary is, whether the person has been prosecuted, officially convicted or participated in some operation, and whether the fund institution is a traditional bank or a virtual bank with half a dozen customers. Once this is discovered, we want to know where the money came from."
Experts attribute the expansion of local funds to regulatory and tax issues.
The Economic Freedom Law of September 2019 gave legal certainty to shareholders and service providers and allowed for more sophisticated structures.
In 2022, two regulatory changes converged to boost the sector: law no. 14,430 gave legal certainty to the securitization of any type of receivable, and CVM resolution 175 reorganized and simplified fund rules, including Fidcs.
The changes coincided with the expansion of independent managers and the deconcentration of the industry, previously dominated by large banks.
Taxation is also a reason for using the vehicle. "You can tax legal entities and individuals. The fund is neither one nor the other — it is in the middle, with different treatment", explains lawyer Thiago Giantomassi, partner for mergers, acquisitions and capital markets at Demarest.
In cascade structures, transactions between companies may be taxed; Between funds, taxation falls on the investor, under the fund's rules.
Critics still see distortions in funds of funds. According to IIFA, Brazil leads in number (10.7 thousand) and proportion (33.1%) in this category, ahead of South Korea (2,000; 11.9%) and the United States (1,268; 10%).
Lawyer Bruno Becker, professor at ESPM, compares the fund industry in 147 jurisdictions in his doctoral thesis from USP. Up to 67% of funds have up to five shareholders, and 44%, one.
His assessment is more critical: he understands that part of the disparity in the international comparison occurs because the majority of funds in Brazil are not funds in practice. "It acts as a heritage organization, as a holding company, but not as a collective savings instrument. They are called funds because someone registered them that way, and the CVM accepted the registration."
According to Becker, in the world, investment funds bring together investors in a diversified portfolio; In Brazil, a fund is also a legal type, even without an economic function.
