Procedure for Conflict Verification No. 001/2026 opened a regulatory investigation into the acquisition of an equity interest in Vasco da Gama SAF, but it did not, by itself, veto the sale. The distinction is central: ANRESF imposed interim measures to limit relationships that could increase a potential conflict while the merits are examined, without declaring the negotiated structure irregular.
As of August 29, 2026, this is the most important point for separating fact from interpretation. ANRESF Communiqué No. 11, released on August 27 and reproduced by outlets that had access to the document, states that opening the procedure is not a judgment on the merits. The agency itself also publicly said that the interim measures are preventive and do not automatically suspend the transaction.
The inquiry is tied to the Financial Sustainability System’s rules on multi-club ownership and cross-influence. Article 86 of the regulation prohibits the same individual or legal entity from directly or indirectly holding control or significant influence over more than one club in competitive situations covered by the rule. In this case, ANRESF wants to determine whether the corporate, financial and family ties associated with the proposal led by Marcos Lamacchia may create that type of influence between Vasco and Palmeiras. That remains under investigation.
What Procedure 001/2026 is investigating
According to the history described in the communiqué and in reports detailing the document, ANRESF’s Technical Unit had been analyzing the transaction since June. After inquiries and the submission of information by Vasco, the technical staff concluded that the matter required deeper examination and recommended opening the formal procedure.
The focus is not simply the family relationship among people connected to the deal. The regulatory question is broader: does there exist, or could there exist, an ability to control or exert significant influence over two clubs that compete in the same environment? The regulation considers factors such as power over financial and operational policies, material veto rights, appointment of key administrators and financing mechanisms that create decision-making power.
For that reason, the existence of the procedure should not be read as a premature conclusion that prohibited multi-club ownership has occurred. It is a verification stage. Vasco, Palmeiras and
companies related to the transaction were notified and may submit statements and documents. Part of the material is being handled confidentially because it involves contractual, corporate and financial data.
What is prohibited between Vasco and Palmeiras during the interim measures
The most visible restriction is the temporary block on direct sporting and commercial relationships between Vasco and Palmeiras in areas capable of creating dependence or coordination. The details published on the basis of Communiqué No. 11 include transfers and loans of players, including youth players, even when no fee is involved.
Financial transactions between the two clubs are also prohibited, along with the sharing of sensitive structures and resources. According to accounts reproducing the interim measure, this includes joint use of training centers, assignment of coaching staff professionals, sharing scouting systems or databases, and exchanging strategic information such as medical data or recruitment planning.
The measure is not a general transfer ban against Vasco. ANRESF has not prohibited the club from signing or selling players to any team in the market. The interim measure targets the relationship with Palmeiras. Deals with other clubs remain subject to the normal rules and, when there is a material financial impact, to the requirements of the judicial reorganization and the Financial Sustainability System.
What is prohibited with Crefisa and Crefipar
The press summarized the interim measure as a ban on doing business with Crefisa, but its scope is more specific. The communiqué, as detailed by UOL, ge and Máquina do Esporte, prohibits new credit relationships for Vasco with companies that appear as guarantors in the Investment Agreement and with their groups or related financial institutions. This group includes Crefipar Participações and Banco Crefisa.
In practice, new loans, financing and equivalent credit structures tied to that group are barred while the interim measure remains in force. The measure is relevant because Banco Crefisa had already extended R$80 million in credit to Vasco in 2025, and entities from the group appear in guarantees associated with the transaction under review.
This does not mean that ANRESF automatically annulled earlier transactions. According to UOL’s detailed account based on the communiqué, relationships formalized before the notification were not undone by the interim measure. The agency is trying to prevent new financial ties from expanding a situation that could later be difficult to reverse.
What remains permitted from ANRESF’s perspective
The SAF sale transaction was not automatically suspended. This is the main practical conclusion from the procedure so far. ANRESF may require adjustments or reach an unfavorable conclusion on the merits, but opening the investigation did not terminate the corporate process and does not replace court decisions in the judicial reorganization.
The clearest evidence that the sale process kept moving came on August 28. Vasco itself said in an official statement that the process to dispose of the UPI Equity was being prepared by order of the 4th Business Court of Rio de Janeiro. On the same day, the notice opening the competitive process for the sale of 90% of the share capital and voting rights of the new SAF was published, allowing potential competing bidders to express interest against the reference proposal.
Therefore, ANRESF’s interim measure and the court proceeding run on different tracks, although they affect one another. The court decides issues related to the judicial reorganization, the UPI Equity and the authorizations required for the transaction. ANRESF examines whether the structure complies with sporting rules on sustainability, independence and multi-club ownership.
Capital contributions from Almirante Participações were not prohibited by the interim measure
Another point that often causes confusion is treating any inflow of money linked to the investor as if it were blocked. The details released about the decision indicate that the credit restriction targets guarantor companies and groups related to Palmeiras and Crefisa, not Almirante Participações in general.
Capital contributions provided for in the agreement with the investor were not automatically covered by the interim measure. Reports from ge and UOL also indicate that any financing directly linked to Almirante Participações does not, for that reason, fall under the same regulatory ban applied to the Crefisa group. This does not mean immediate financial clearance: any transaction that depends on the judicial reorganization court remains subject to judicial authorization and the other conditions of the proceeding.
In other words, a transaction can be outside ANRESF’s prohibition and still be unable to proceed at that moment because court authorization is lacking. Mixing these two levels creates the mistaken impression that the sports agency alone approved or blocked everything.
The investor also faces a governance restriction
The interim measure does not concern only money and relationships between clubs. Communiqué No. 11 also restricts, before ANRESF’s final approval, the appointment of people directly or indirectly linked to the investor to administrative, management or strategic decision-making positions at Vasco.
This restriction helps explain the preventive logic of the decision. Even without stopping the transaction, the agency is trying to avoid having the command structure changed irreversibly before it concludes whether a conflict of influence exists. The deal may therefore continue to be analyzed and structured, but certain governance effects remain frozen during the investigation.
If there is a conflict, will the sale necessarily be vetoed?
Not necessarily. Article 86 of the Financial Sustainability System Regulation itself provides remediation mechanisms when a prohibited situation is identified. Alternatives include establishing a blind trust previously approved and supervised by ANRESF, selling equity interests, or taking another measure capable of producing effective separation.
This does not turn a blind trust into automatic approval. The mechanism must be accepted and supervised by the agency, and the specific structure must actually remove prohibited control or influence. The investigation exists precisely to determine whether the proposed design meets that standard or needs to be changed.
It is also premature to say that the agency will certainly veto or certainly approve the transaction. The procedure is still underway, relevant material is partly confidential, and the merits depend on the technical analysis of corporate, financing and governance ties.
What to watch next
The next truly decisive milestone is not another headline about the existence of the investigation, but ANRESF’s conclusion on whether there is control or significant influence incompatible with Article 86 and, if so, which remediation measures will be required.
At the same time, the UPI Equity competitive process continues in court. Publication of the notice on August 28 shows that the sale was not blocked by the agency’s interim measures. It also shows that Marcos Lamacchia’s proposal is not the same as a completed acquisition: other interested parties may come forward under the rules of the court proceeding.
The most precise reading, therefore, is this: ANRESF has not given final approval to the sale, nor has it prohibited it at this point. It isolated specific relationships with Palmeiras and related financial groups, restricted governance changes, and opened a formal investigation to decide whether the structure can coexist with Brazilian football’s integrity rules.
