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Squadra Investments - Gestao de Recursos Ltda.: investment adviser

Squadra Investments - Gestao de Recursos Ltda. is an investment adviser registered with the SEC (file 801-74352, CRD 160366). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.

Assets managed
$2.1B
Discretionary
100%
Accounts
6
Employees
27
In advisory roles
23
Disclosures
1

Company page · SEC adviser record · Full Form ADV (PDF)

The firm reports no custody of client cash or securities.

Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.

Clients and fees

Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.

Client typeClientsAssetsShare
Private funds and other pooled vehicles7$1.5B72.3%
Sovereign wealth funds1$425.4M20.4%
Other: Endowment1$151.5M7.3%

How it is paid

  • A percentage of assets under your management
  • Performance-based fees

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)
  • Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles)

Who owns it

Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.

Direct owners (Schedule A)

OwnerTypeRoleStakeSinceControlPublic company
Guilherme Mexias AchePersonCEO/co-D 50% to 75%Dec 2007Yes
Eduardo Valentim De AraujoPersonPartnerB 10% to 25%Dec 2007Yes
Luiz Mauricio De Miranda E SilvaPersonCo-CIOB 10% to 25%Dec 2007Yes
Felipe Dutra CanÇAdoPersonPartnerA 5% to 10%Feb 2016Yes

Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.

Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.

Disciplinary history

What the firm disclosed under Item 11 of Form ADV. A disclosure is the firm's own report: pending matters are allegations, not findings, and many settlements are made without admitting or denying them. Text is quoted from the filing, set in sentence case.

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

  • Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?

Actions about affiliates (1)

  1. Aug 21, 2007
    Regulatory Action: SEC FinalAbout an affiliate: Ache, Guilherme, MexiasSanctions: Other; Administrative warning.no more severe penalty was imposed against defendant, among others, because information was received · Resolved Aug 21, 2007 · Decision · Docket PROCESSO ADMINISTRATIVO SANCIONADOR CVM Nº SP 2005/0155

    Accusation of insider trading, based upon suspicion that MR. achÉ, as an equity analyst in JGP S.A., entered into transactions in his own name and in the name of an investment vehicle under JGP's management, based upon privileged information obtained in the ordinary course of its functions as an analyst at JGP. Generally, the defense was based upon the fact that the information has been provided by the target company during business meeting, with no obligation of MR. Ache to confirm the privileged nature of such information.

    See item 2.

    The action is currently closed in regard to MR. Ache. No information Filed

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.

The brochure

Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.

Squadra Investments Form ADV Part 2A, filed Mar 31, 2026. Brochure PDF. Items: 4 · 5 · 6

Item 4. Advisory business

Broker-dealer and Commodity pool registration Luis Augusto Oliveira Gambôa is not actively engaged in any investment-related business or occupation as a broker- dealer, registered representative of a broker-dealer, futures commission merchant (“FCM”), commodity pool operator (“CPO”), commodity trading advisor (“CTA”), or an associated person of an FCM, CPO, or CTA. The Firm has made exemption filings on behalf of certain Funds with the CFTC. Luis Augusto Oliveira Gambôa does not receive commissions, bonuses or other compensation based on the sale of securities or other investment products. Conflict of interest in material relationships Squadra Investimentos – Gestão de Recursos Ltda.

Read the rest of Item 4 (60 more words)

(“Squadra Investimentos”) is an affiliated Brazilian investment management firm registered with the Comissão de Valores Mobiliários - CVM (Securities and Exchange Commission of Brazil). Squadra Investimentos manages funds for Brazilian investors. The

company was founded in December 2007 and the first funds were launched in March 2008. Luis Augusto Oliveira Gambôa is partner of both Squadra Investimentos and the Firm.

Item 5. Fees and compensation

Luis Augusto Oliveira Gambôa does not receive any economic benefit from someone who is not a client including based on number or amount of sales, client referrals, or new accounts.

Item 6. Performance-based fees and side-by-side management

Luis Augusto Oliveira Gambôa is a trader/analyst of the Firm. He is supervised by the CEO/coCio, Guilherme Mexias Aché, and the co-CIO, Luiz Mauricio de Miranda e Silva, who monitor and comanage the portfolios. Please see telephone number at cover page.

Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.