ANM amends the procedure for investigation of infractions and sanctions in the mining sector

On October 24, 2025, the Board of Directors of the National Mining Agency (ANM) published Resolution ANM No. 223/2025, establishing new procedures for the investigation of infractions, the application of sanctions, and the calculation of fines arising from noncompliance with obligations set forth in Brazilian mining legislation. A Glossary is attached to the last page of this Article.

The regulation, which will revoke Resolutions ANM Nos. 122/2022, 136/2023, 145/2023, 151/2024 and Article 15 of Resolution ANM No. 156/2024, will enter into force thirty (30) days after its publication, introducing a substantial overhaul of the mineral sanctioning regime, with new criteria for classification, typification, and proportionality of penalties.

Structure and Scope of the New Regulation

Resolution ANM No. 223/2025 distinguishes between pecuniary and non-pecuniary sanctions, introducing a more detailed classification of gravity levels and operational scales.

As per Article 229, daily fines remain applicable whenever an infraction (i) persists over time, (ii) poses a risk to human life or health, or (iii) causes damage to the environment or to the rational exploitation of mineral deposits.

The total amount of daily fines may not exceed R$1,000,000,000.00 (one billion reais), and infractions are classified into eight groups (I to VIII) and up to five levels of gravity, according to their nature and the extent of the resulting damage, as set forth in Article 20 of the Resolution.

Group I – Financial Compensation for the Exploitation of Mineral Resources (CFEM): covers irregularities in the assessment, declaration, or payment of CFEM, subject to fines of up to thirty per cent (30%) of the assessed amount or R$ 5,000.00 (five thousand reais), whichever is greater, depending on the infraction.

Group II – Mineral Exploration: encompasses noncompliance with obligations related to the exploration phase, with severity levels ranging from 1 to 4, and fine amounts determined according to Article 57 and Annex II.

Group III – Documents and Legal Deadlines: addresses violations related to the submission of mandatory documents, compliance with deadlines, and other formal obligations, with severity levels from 1 to 5, and fines calculated based on Article 55(III) and the methodology established in Article 56.

Group IV – Environmental Impacts: refers to conduct that causes direct or indirect environmental damage resulting from mining activities, with severity levels from 1 to 5, and fines calculated in accordance with Articles 55 (III) and 56.

Group V – Economic Exploitation of Mineral Resources: includes violations related to mine operation and the economic use of mineral resources, applying the same criteria for gravity and calculation basis.

Group VI – Operational Safety of Activities: involves noncompliance with safety requirements for mines, tailings dams, and other operational structures, with severity levels from 1 to 5, and fines calculated as set out in Articles 55 and 56.

Group VII – Risks to Populations and Human Life: covers conduct that exposes communities, workers, or neighboring populations to risk, subject to the same parameters of gravity and calculation.

Group VIII – Impacts on Third Parties and Cultural Heritage: refers to damage or risks to properties, communities, or cultural assets associated with mining activities, also subject to severity levels from 1 to 5.

Sanctioning System – Breakdown by Group (Arts. 21 to 28)

Group I – CFEM (Art. 21)

Calculation basis (Art. 55, I): Assessed CFEM Value reported in the DIEF-CFEM.
Maximum fine (Art. 20, I): up to 30% of the assessed value or R$ 5,000, whichever is greater.

Sanctionable conduct (head provision): I) submission of false or inaccurate declarations or information regarding CFEM; II) forgery, alteration, destruction, simulation, or manipulation of accounting records, books, or other documents required for CFEM inspection; III) unjustified refusal to provide documents requested by ANM in proceedings related to CFEM; IV) underreporting or undercalculation of the CFEM amount due.

Specific rules:

Article 21, §1: “Assessed value” refers to the consolidated CFEM debt after inspection, including principal amount, monetary adjustment, interest, and late payment fine.

Article 21, §2: Under item III, the “assessed value” equals the highest monthly CFEM value (adjusted) from the previous fiscal year multiplied by the number of months audited.

Article 21, §3: In the absence of data, the base value will be arbitrated based on projected production (Mining Plan × market price of the mineral commodity).

Article 21, §4: The fine applies only to the taxable events that resulted in the infraction.

Article 21, §5: For items I and II, the fine corresponds to twenty per cent (20%) of the assessed value (§1) or five thousand reais (R$ 5,000.00), whichever is greater.

Article 21, §6: For item IV, the fine corresponds to thirty per cent (30%) of the assessed value (§1).

Article 21, §7: For item III, the fine corresponds to zero point thirty-three per cent (0.33%) per day, up to a maximum of twenty per cent (20%) of the assessed value (§2).

Group II – Mineral Exploration (Art. 22)

Calculation basis (Art. 55, II): Average price per hectare from the 5th Round of the ANM’s Area Availability Process (twenty-one reais and eighty-two cents [R$ 21.82], adjusted by the IPCA).

Specific fine calibration (Art. 57):

– Factors include gravity, economic capacity (total authorized area: small ≤ 3,500 ha; medium > 3,500 and ≤ 11,500 ha; large > 11,500 ha), past record, and aggravating/mitigating circumstances.

– The base fine (Annex II) is adjusted by adding aggravating factors, subtracting mitigating ones, and then applying any recurrence increases.

Infractions by severity level:

Group II-1 (Level 1): (I) failure to pay or late payment of the Annual Fee per Hectare (TAH); (II) failure to submit corporate documents or amendments to the ANM within thirty (30) days of registration; (III) hindering inspections or refusing to provide information to ANM agents.

Group II-2 (Level 2): (I) noncompliance with deadlines for starting or resuming exploration; (II) interruption of exploration without justification for over three consecutive months or one hundred and twenty (120) cumulative days; (III) failure to notify ANM of the start, restart, or suspension of works; (IV) failure to report the discovery of another useful mineral substance; (V) failure to submit geological survey results; (VI) failure to report technical-economic data, chemical analyses, or technical reports; (VII) failure to submit the DIPEM by April 30 each year.

Group II-3 (Level 3): (I) failure to submit the Final Research Report (RFP) within the title’s validity; (II) providing false information or data to public authorities; (III) carrying out exploration without authorization or in breach of the license and environmental law; (IV) failure to assign technical responsibility to a licensed mining engineer or geologist.

Group III – Legal Documents and Deadlines (Art. 23)

Calculation Basis (Art. 55, III): Mineral Production Value (VPM), based on the most recent of the last five reference years, adjusted by the IPCA.

Methodologies (Arts. 56 and 58): Apply both Methodology I (percentage over VPM) and Methodology II (interpolation by economic range); the lower final value must prevail, and both calculations must be explicitly stated in the administrative decision.

Infractions by severity level:

Group III-1 (Level 1): (I) failure to fill out the EIR (Regular Inspection Summary) in SIGBM within the deadline; (II) failure to issue or submit the DEE (Emergency Closure Declaration) in SIGBM; (III) failure to comply with the minimum content requirements of the RCIE (Special Inspection Conclusive Report); (IV) failure to comply with the minimum content of the RCCA (Accident Causes and Consequences Report).

Group III-2 (Level 2): (I) PLG (Garimpeira Mining Permit): failure to start extraction within ninety (90) days of publication (unless justified); (II) Mining Concession: failure or delay in submitting corporate documents or shareholder agreements; (III) Exporters: failure to inform the ANM within thirty (30) days of the expiration of an unused Kimberley Process Certificate; (IV) failure to keep registration data and address updated; (V) failure to prepare, maintain, or submit Volumes I, II, and III (items 1–5) of the PSB (Dam Safety Plan); (VI) failure to meet the minimum content requirements of the RPSB (Periodic Dam Safety Review); (VII) failure to meet the minimum content of the RISR (Regular Inspection Report); (VIII) failure to meet the minimum content of the PGRBM (Risk Management Process); (IX) failure to possess or submit the RPSB at the required frequency.

Group III-3 (Level 3): (I) failure to meet start or restart deadlines for mining operations; (II) suspension of operations without prior notice to ANM; (III) failure to present the mine closure plan within thirty (30) days after title expiration or revocation; (IV) PLG: failure to submit exploration projects requested by ANM within ninety (90) days; (V) Cooperatives: failure, delay, or submission of false or inaccurate member lists; (VI) Titleholders: failure, delay, or submission of false or inaccurate lists of miners under partnership contracts; (VII) CFEM payers: failure to register or update data with ANM; (VIII) failure or delay in submitting the DIEF-CFEM (per Resolution ANM No. 156/2024); (IX) First purchaser (PLG): failure to keep registration data updated; (X) RTC (Commercial Transactions Report): failure to fill out, incomplete or incorrect completion, or late submission; (XI) Non-ferrous metal concessions: failure to submit quarterly statistical maps of production and sales; (XII) failure to submit the RCCA.

Group III-4 (Level 4): (I) failure by auction winners subject to CNCD registration to enroll; (II) failure to submit to ANM the annual activity report by March 15 each year; (III) in the Annual Mining Report, failure to provide required information or providing false data; (IV) Licensing regime: failure to submit the simplified annual report by March 31; (V) Rough diamond producers: failure to declare the RTC; (VI) failure to comply with regulatory standards, as specified in Group III of Annex IV-A.

Group IV – Environmental Impacts (Art. 24)

Calculation Basis (Art. 55, III): Mineral Production Value (VPM) based on the Annual Mining Report (RAL), as a general rule.

Infractions by severity level:

Group IV-3 (Level 3): (I) failure to comply with obligations until mine closure (plan approved by both ANM and the environmental authority); (II) failure to take responsibility for damages or losses to third parties resulting from mining operations; (III) failure to prevent air or water pollution; (IV) failure to remove equipment or goods from mines under closure; (V) causing damages or losses to third parties resulting directly or indirectly from mining.

Group IV-4 (Level 4): (I) failure to decommission installations and equipment; (II) failure to prevent leakage or drain water that could cause harm to neighboring properties; (III) in mineral water extraction, failure to protect and preserve springs or to use water according to technical standards; (IV) failure to prevent sewage or wastewater leakage, or to drain and treat waters that may cause harm to others.

Group IV-5 (Level 5): (I) failure to restore degraded environments, including mine closure, decommissioning, and tailings dam structures; (II) failure to execute or adequately conclude the mine closure plan before the expiration of the mining title; (III) unauthorized mineral extraction or extraction conducted without environmental compliance; (IV) failure to comply with regulatory standards, as established in Group IV of Annexes IV-A to IV-E.

Group V – Economic Exploitation (Art. 25)

Calculation Basis (Art. 55, III): Mineral Production Value (VPM), based on the Annual Mining Report (RAL), as a general rule.

Infractions by severity level:

Group V-2 (Level 2): (I) failure to propose necessary amendments to the Economic Exploitation Plan (PAE); (II) failure to notify the ANM of the discovery of another mineral substance not included in the granted title or regime.

Group V-3 (Level 3): (I) failure to initiate activities under the PAE within six (6) months of its publication, except in cases of duly proven force majeure.

Group V-4 (Level 4): (I) acquiring a mineral product from a PLG (Garimpeira Mining Permit) without prior registration in the First Purchaser Registry; (II) selling a PLG mineral product to an unregistered buyer (applicable to the PLG holder who executed the transaction); (III) failure by gold or rough diamond producers to register with the National Diamond Trade Registry (CNCD); (IV) conducting mining operations inconsistently with the approved PAE; (V) failure to entrust mining operations to a qualified professional; (VI) failure to comply with ANM inspection determinations; (VII) during temporary suspension, failure to maintain the mine in proper condition; (VIII) failure to comply with specific regulations on the purchase, sale, and transport of gold or diamonds by the first purchaser (PLG).

Group V-5 (Level 5): (I) extracting unauthorized mineral substances; (II) engaging in improper mining practices (“lavra ambiciosa”) that render future exploitation unfeasible; (III) abandoning a mine or deposit; (IV) providing false or misleading information to public authorities; (V) failure to comply with regulatory mining standards, as established in Group V of Annexes IV-A to IV-E.

Group VI – Operational Safety (Art. 26)

Calculation Basis (Art. 55, III): Mineral Production Value (VPM), based on the Annual Mining Report (RAL), as a general rule.

Infractions by severity level:

Group VI-1 (Level 1): (I) failure to keep responsible personnel data updated in the SIGBM; (II) noncompliance with minimum requirements for technical documents or team composition; (III) failure to submit the Declaration of Stability Condition (DCE) from the Periodic Dam Safety Review (RPSB); (IV) failure to possess or present the Regular Inspection Report (RISR) at the required frequency.

Group VI-2 (Level 2): (I) failure to conduct the Regular Safety Inspection (ISR) as prescribed in Resolution ANM No. 95/2022; (II) failure to conduct the Special Safety Inspection (ISE); (III) incorrectly filling out information in SIGBM (without benefit to the entrepreneur); (IV) failure to comply with the minimum content requirements of the flood map; (V) failure to maintain controlled vegetative cover on dam slopes; (VI) failure to comply with ANM inspection measures under the National Dam Safety Policy (PNSB); (VII) failure to submit the DCE from the RISR; (VIII) failure to possess or submit the Special Inspection Conclusive Report (RCIE); (IX) failure to conduct the Annual Compliance and Operability Assessment (ACO) of the Emergency Action Plan for Mining Dams (PAEBM); (X) failure to possess or implement the Risk Management Process (PGRBM).

Group VI-3 (Level 3): (I) failure to include auxiliary containment structures, flood maps, and risk analyses in studies and plans; (II) Engineer of Record (EdR): failure to continuously evaluate structures and issue reports and ARTs; (III) failure to forward to ANM, within seventy-two (72) hours, the electronic receipt in SEI for emergency or risk notifications; (IV) failure to perform periodic evaluations of drained stacks or to maintain documentation available for inspection; (V) failure to maintain a dam safety monitoring system; (VI) failure to designate an Engineer of Record (EdR); (VII) failure to implement or operationalize the PAEBM.

Group VI-4 (Level 4): (I) failure to monitor or track tailings/waste disposal systems, geotechnical stability, servitude areas, aquifer behavior, and drainage systems; (II) interrupting mining operations already initiated for more than six (6) consecutive months (except for proven force majeure); (III) obstructing inspection or denying information to ANM agents; (IV) failure to adopt occupational health and safety measures; (V) failure to ensure the safety and habitability of existing dwellings; (VI) failure to report in SIGBM within twenty-four (24) hours an anomaly with a score of ten; (VII) failure to immediately register drained stacks susceptible to liquefaction; (VIII) failure to inform reclassification to high CRI (Risk Category); (IX) failure to comply with recommendations from the RPSB; (X) failure to comply with recommendations from the RISR; (XI) allowing the presence of unauthorized persons in the Self-Rescue Zone (ZAS).

Group VI-5 (Level 5): (I) for dams under construction, failure to comply with ABNT NBR 13.028/2017 standards; (II) failure to consider the minimum return period in spillway design; (III) failure by the entrepreneur to provide resources for dam safety and damage repair (until structure deregistration); (IV) construction of new dams where the flood map identifies communities within the Self-Rescue Zone (ZAS); (V) failure to possess a technical project, execute works, or decharacterize upstream tailings dams (or those with unknown construction methods); (VI) performing unauthorized dam raises outside the exceptions provided in the executive project for decharacterization; (VII) failure to maintain continuous and effective structural stability or to declare it periodically; (VIII) failure to recover, deactivate, or decharacterize dams that do not meet safety standards; (IX) failure to maintain safe conditions in containment structures, or to comply with applicable legislation, engineering plans, or environmental license conditions; (X) failure to cease effluent or tailings discharge when required; (XI) failure to comply with regulatory standards, as defined in Group VI of Annexes IV-A to IV-E.

Group VII – Risks to Human Life (Art. 27)

Calculation Basis (Art. 55, III): Mineral Production Value (VPM), based on the Annual Mining Report (RAL), as a general rule.

Infractions by severity level:

Group VII-2 (Level 2): (I) failure to comply with the minimum content requirements of the Emergency Action Plan for Mining Dams (PAEBM).

Group VII-3 (Level 3): (I) using labels with wording different from those approved by ANM; (II) failure to install automated siren systems outside the flood zone and effective alert mechanisms in the Self-Rescue Zone (ZAS); (III) failure to possess or present the flood map.

Group VII-4 (Level 4): (I) offering for sale or consumption water not authorized by a mining decree; (II) offering for sale water from a different source; (III) failure to possess or present the PAEBM; (IV) failure to register all dams (under construction, in operation, or decommissioned) and downstream containment structures (ECJ) at the required frequency.

Group VII-5 (Level 5): (I) selling or using water in unhygienic or unsuitable conditions; (II) denying unrestricted access to ANM, environmental licensing authority (Sisnama), civil defense, or public safety agencies to the dam site, associated installations, or safety documentation; (III) providing false or misleading declarations, falsifying, tampering with, or altering official records or documents that benefit the operator; (IV) failing to alert the population in the ZAS when Emergency Level 3 is declared; (V) failing to immediately notify ANM, the environmental licensing authority, and civil defense of any change in dam safety conditions that could lead to an accident or disaster; (VI) constructing, maintaining, or operating in the ZAS installations, structures, or services prohibited under Resolution ANM No. 95/2022; (VII) failure to comply with regulatory standards, as established in Group VII of Annexes IV-A to IV-E.

Group VIII – Impacts on Third Parties and Cultural Heritage (Art. 28)

Calculation Basis (Art. 55, III): Mineral Production Value (VPM), derived from the Annual Mining Report (RAL), as a general rule.

Infractions by severity level:

• Group VIII-5 (Level 5): (I) failure to decharacterize the dam, resettle affected populations, preserve or recover cultural heritage, or execute structural reinforcements ensuring effective stability in dams built or operated before Law No. 14,066/2020, when there are communities located in the Self-Rescue Zone (ZAS), as defined by IBGE’s classifications (urban areas, rural clusters, subnormal settlements, or villages); (II) failure to comply with regulatory standards, as established in Group VIII of Annexes IV-A to IV-E.

Parameters and Calculation Bases (Art. 55)

Article 55 establishes the economic reference bases for calculating the fines imposed under the sanctioning framework:

1. Group I: uses the CFEM Assessed Value declared in the DIEF-CFEM, pursuant to §§ 1 and 2 of Art. 21.
2. Group II: adopts the average hectare price from the 5th Round of the ANM’s Area Availability Program, set at twenty-one reais and eighty-two cents (R$ 21.82), adjusted by the IPCA.
3. Groups III to VIII: use the Mineral Production Value (VPM) reported in the Annual Mining Report (RAL), or its equivalent, taking as reference the most recent value among the previous five base years prior to the initiation of the Administrative Sanctioning Proceeding (PAS), adjusted by the IPCA.

If the calculation base cannot be determined due to missing information, ANM may arbitrate the following:

• Group II: the value corresponding to the medium-scale range;
• Groups III to VIII: the median value of the most recent available VPM distribution.

The violator may present documentary evidence during the defense period to correct the classification of the arbitrated base.

Methodology and Fine Dosimetry (Art. 56)

The determination of the final fine amount takes into account the following factors: severity of the infraction, resulting damages, economic capacity of the offender, prior infractions, and mitigating or aggravating circumstances.

Calculation Methodologies (Groups III to VIII)

ANM applies two distinct calculation methodologies, adopting the lower value obtained as the basis for determining the fine amount:

• Methodology I: applies a reference percentage to the Mineral Production Value (VPM) according to the severity level defined in Annex I-A.
• Methodology II: employs interpolation between minimum and maximum values, based on both the severity level and the offender’s economic capacity tier, as defined in Annex I-B, observing the following segmentation:
  • Tier C – Small scale: VPM up to four million and eight thousand reais (R$ 4,800,000.00);
  • Tier B – Medium scale: VPM between four million and eight thousand reais (R$ 4,800,000.00) and seventy-eight million reais (R$ 78 million);
  • Tier A – Large scale: VPM above seventy-eight million reais (R$ 78 million).

 

Faixa / Gravidade		1	2	3	4	5
Faixa C	Mínimo	5.316,25	5.316,25	5.316,25	5.316,25	5.316,25
	Máximo	6.500,00	8.500,00	11.900,00	23.800,00	95.200,00
Faixa B	Mínimo	7.200,00	9.400,00	13.100,00	26.200,00	104.700,00
	Máximo	20.200,00	58.600,00	175.800,00	580.100,00	2.320.400,00
Faixa A	Mínimo	22.200,00	64.500,00	193.400,00	638.100,00	2.552.400,00
	Máximo	66.600,00	266.400,00	1.332.000,00	7.992.000,00	55.944.000,00

Source of table: Annex to Resolution ANM No. 223/2025.

After determining the base value, aggravating and mitigating factors, as well as recidivism, are applied in accordance with Articles 53 and 59. Proven damages recorded in the case file are treated as aggravating circumstances, and the offender’s prior record may increase the penalty.

The final amount of the fine shall correspond to the lower result obtained between the two methodologies, while respecting the minimum and maximum limits established under sectoral legislation.

Specific Calculation for Mineral Exploration (Art. 57)

For Group II (exploration phase), the fine takes into account:

• severity of the infraction, economic capacity, prior record, and mitigating/aggravating circumstances. The economic capacity is determined based on the total area covered by active exploration permits:
• Small scale: up to three thousand and five hundred (3,500) hectares;
• Medium scale: between three thousand and five hundred (3,500) and eleven thousand and five hundred (11,500) hectares;
• Large scale: above eleven thousand and five hundred (11,500) hectares.

Escala / Gravidade	1	2	3	4
Pequena Escala	5.316,25	8.700,00	13.100,00	17.500,00
Média Escala	8.700,00	17.500,00	26.200,00	34.900,00
Grande Escala	13.100,00	26.200,00	39.300,00	52.400,00

Source of table: Annex to Resolution ANM No. 223/2025.

O valor final decorre do valor-base previsto no Anexo II, acrescido de agravantes, reduzido pelas atenuantes, e ajustado conforme reincidência (art. 53).

Aggravating and Mitigating Factors (Arts. 59 and 60)

The fine amount may be increased or reduced depending on the circumstances:

Aggravating Factors – Art. 59

• +0.1 (10%) if the offender has 1 to 5 final sanctions in the last five years;
• +0.2 (20%) if the offender has 6 to 10 sanctions;
• +0.3 (30%) if the offender has 11 or more sanctions;
• +0.1 to +20.0, depending on the extent of the damage (Annex V).

Mitigating Factors – Art. 60

• –60% in cases of waiver of appeal and payment within 20 days after notification of the infraction notice (Art. 42);
• –25% if the offender voluntarily adopts effective measures to prevent or mitigate the damage before the first-instance decision.

Non-Pecuniary Sanctions

Non-pecuniary infractions correspond to administrative measures of a non-financial nature, which may be applied either individually or cumulatively. These include: warning, suspension, interdiction, embargo, seizure, demolition, cancellation, restrictive sanctions on rights, and, in cases of noncompliance or continued infraction, a daily coercive fine.

Administrative Sanctioning Procedure

The administrative procedure establishes defined stages and deadlines, ensuring both the right to defense and legal certainty:

1. Issuance and notification of the infraction notice;
2. Submission of a written defense within twenty (20) calendar days, during which the defendant may acknowledge the infraction and waive the right to appeal, in which case the fine amount is reduced (Arts. 38 and 42 §1).
3. First-instance decision, which may result in archiving, declaration of nullity, or imposition of a sanction.
4. Administrative appeal within twenty (20) calendar days, addressed to the superintendent responsible for the judging unit (Art. 41).
5.  Second-instance appeal to the ANM Collegiate Board, whose decision exhausts the administrative process and constitutes an enforceable title for the fine (Art. 47).

Final Considerations

The Resolution ANM No. 223/2025, scheduled to take effect on November 23, 2025, introduces significant adjustments to the sanctioning system applicable to the mining sector. The new regulation updates provisions of Resolution ANM No. 122/2022, incorporating additional parameters for classifying infractions and methodologies for calculating administrative penalties.

Among the main changes, the regulation standardizes the calculation bases, including the Financial Compensation for Mineral Resource Exploitation (CFEM), the price per hectare, and the Mineral Production Value (VPM), and introduces economic scale tiers, applicable according to the holder’s profile and the severity of the infraction. The text also provides for the use of dual calculation methodologies, combining percentage-based and interpolation criteria by economic tier, with the aim of ensuring proportionality between the conduct and the applicable sanction.

The new framework establishes specific rules regarding aggravating and mitigating factors, as well as recurrence, and introduces parameters for estimated assessments in cases where there is insufficient information to determine the reference base. It also includes provisions addressing documentary, environmental, operational safety, and economic utilization infractions, organized into eight thematic groups.

In light of the forthcoming entry into force of the Resolution, it is advisable for titleholders and operators to review their internal compliance and monitoring procedures to ensure that technical reports, mandatory communications, and CFEM and TAH controls are aligned with the updated administrative criteria.

The CMA Energy and Natural Resources Team is available to provide further clarification on this topic.

 

 

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GLOSSARY

 

ANM (National Mining Agency): The Brazilian regulatory and inspection authority for the mining sector.

Resolution No. 223/2025: The new regulation published by ANM establishing updated procedures for investigating infractions, applying sanctions, and calculating fines in the mining sector.

Pecuniary Sanctions: Financial penalties, primarily fines (multas), imposed for noncompliance.

Non-Pecuniary Sanctions: Administrative measures of a non-financial nature, such as warning, suspension, interdiction (embargo), seizure (apreensão), demolition, cancellation, and restrictive sanctions on rights.

CFEM (Financial Compensation for the Exploitation of Mineral Resources): A royalty or levy due to the government on the exploitation of mineral resources in Brazil.

DIEF-CFEM (Declaration of Information regarding CFEM): The mandatory declaration submitted to ANM detailing the assessment, calculation, and payment information for the CFEM royalty.

TAH (Annual Fee per Hectare): A fee paid to the ANM by titleholders during the mineral exploration phase, calculated based on the area size.

RFP (Final Research Report): The mandatory technical document submitted to ANM at the end of the mineral exploration phase, reporting all findings and activities.

VPM (Mineral Production Value): The total value of mineral production, a key economic metric used as the calculation base for fines under the new resolution.

RAL (Annual Mining Report): A mandatory report submitted annually to ANM by titleholders, detailing production, sales, costs, and VPM information for the previous year.

IPCA (Broad National Consumer Price Index): The official inflation index used in Brazil, referenced for adjusting the monetary value of fine calculation bases.

PAE (Economic Exploitation Plan): The technical plan detailing how the mineral deposit will be mined and economically utilized.

PLG (Garimpeira Mining Permit): A specific regime for mineral extraction, generally applying to small-scale or artisanal miners (garimpeiros).

CNCD (National Diamond Trade Registry): A mandatory registration system for entities involved in the trade of diamonds in Brazil.

RTC (Commercial Transactions Report): The mandatory report detailing commercial transactions related to mineral commodities, especially rough diamonds.

PSB (Dam Safety Plan): The mandatory technical plan outlining the safety procedures and maintenance for tailings dams and other containment structures.

RPSB (Periodic Dam Safety Review): A regular, mandatory, and comprehensive review of a dam’s safety conditions.

RISR (Regular Inspection Report): A technical report resulting from the Regular Safety Inspection (ISR) of a dam (Resolution ANM No. 95/2022).

PGRBM (Risk Management Process for Mining Dams): The systematic process for identifying, analyzing, evaluating, and treating risks associated with mining dams.

PAEBM (Emergency Action Plan for Mining Dams): The mandatory plan detailing response actions and procedures to be followed in case of a dam safety incident or emergency.

DCE (Declaration of Stability Condition): A mandatory document declaring the stability status of a dam, submitted after safety inspections or reviews.

ZAS (Self-Rescue Zone): The area immediately downstream of a dam that would be reached by a flood wave within a short time (e.g., 30 minutes), requiring immediate and independent action by the population.

CRI (Risk Category): The classification system used by ANM to categorize the risk level of mining dams (e.g., low, medium, or high risk).

PAS (Administrative Sanctioning Proceeding): The formal administrative process initiated by ANM to investigate an infraction and potentially apply sanctions.

First Purchaser Registry: A mandatory registry for entities that acquire mineral products from PLG operations.