The police filing states that the bank allegedly structured its shareholding through a series of investment funds — Josephina I, II, and later Josephina III — to disguise who the real owners were, thereby concealing that a shareholder threshold had been crossed that legally obligated a tender offer .
Police delegate José Eduardo Jorge concluded there was "conscious participation" by both Acosta and Reinig in the scheme, and that the bank used "opaque legal structures" to hide beneficial ownership, harming minority shareholders who were denied the tender offer they were entitled to .
According to reports, the tender offer that was allegedly evaded was valued at approximately R$6 billion (about $1.1 billion) .
The police document asserts that the executives aimed to induce error in the company itself, the Brazilian securities regulator CVM (Comissão de Valores Mobiliários), the B3 stock exchange, and investors .
Goldman Sachs has stated that it intends to contest the allegations vigorously. The bank says it acted properly and is cooperating with authorities. A spokesperson said the bank believes the police's conclusions are unfounded and that it will present its evidence in the appropriate legal proceedings .
As of the latest reports, no formal criminal charges have been filed by prosecutors yet; the police indiciamento (formal accusation) is the first step, which will now be reviewed by the Public Prosecutor's Office, which will decide whether to press charges .
The indictment does not constitute a conviction but opens a formal criminal investigation phase. If prosecutors accept the police findings, the case moves to court where the accused can present their defense. Both executives remain employed at Goldman Sachs during the proceedings, though their positions could face scrutiny .