CADE signs agreement after gun jumping investigation

On 27 May, the Administrative Council for Economic Defense (CADE) signed an agreement with AZ Quest Holdings, AZ Brasile Holding, and XP Managers Fundo de Investimento em Participações Multiestratégia as part of the administrative procedure for merger review launched to investigate the acquisition of 5% of AZ Quest’s shares by XP Managers, previously held by AZ Brasile.

The transaction was formalised in October 2021 and completed in January 2022; however, it was notified to CADE in July 2025.

Diogo Thomson, rapporteur of the case and interim president of the agency, identified the practice of gun jumping, considering that the transaction should have been submitted to CADE for review in advance, as it met the legal criteria for mandatory notification.

In order to conclude the investigation, the companies proposed an agreement committing to pay a financial contribution of BRL 2,783,094.32 to the Brazilian Fund for De Facto Joint Rights (FDD), which must be paid in a single instalment within 60 days after the publication of the agreement.

The Tribunal of CADE unanimously approved the proposal.