Understanding Refit Group’s Asset Hiding Network

Offshore companies helped Refit hide assets stemming from a fraud and tax evasion scheme targeted by a massive federal revenue operation Thursday, according to investigators. These US-registered companies appear to own investment funds that received amounts illegally obtained by the suspects.

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The amount obtained through the scheme was reallocated across a network of orange companies, mainly through holding companies, offshore companies, payment institutions and investment funds.

Federal Revenue highlights that 17 funds linked to the group have been identified so far, with total assets of R$8 billion. Most often, funds have only one shareholder, who in turn is another investment fund. In this way, the suspects created “layers of concealment,” making it difficult to trace the flow of money.

Analysis of the funds led investigators to foreign entities established in the state of Delaware, USA. The US state is known for creating facilities for companies that want to establish themselves there, granting a high degree of anonymity and the absence of local taxes, provided that companies do not generate income on US soil.

“This practice is usually associated with strategies aimed at money laundering or protecting the assets of those involved,” the Federal Revenue Service said, adding: “More than 15 offshore companies have already been identified in the United States, which send resources to acquire shares and real estate in Brazil, totaling about R$ 1 billion.”

According to the Inter-Institutional Commission for Asset Recovery of the State of São Paulo, several companies linked to the group acted as “intermediary persons” (oranges) to avoid paying ICMS:

“Criminal acts occur through repeated tax noncompliance, use of companies with corporate and operational relationships and simulating interstate fuel operations,” the commission’s memo says.

The importers, who also acted as orange companies, were used to source naphtha, hydrocarbons and diesel from abroad with money from the group’s manufacturers and distributors. Between 2020 and 2025, the people investigated imported about R$32 billion worth of fuel, and companies linked to the group “repeatedly evaded taxes in their operations,” according to the Federal Revenue Service.

The funds were concentrated in the group’s financial companies. Between the second half of 2024 and the first half of 2025, more than R$72 billion was transferred through this nucleus, formed by a financial “parent” company, which controls smaller companies. The group also used so-called “pocket accounts” and exploited a regulatory loophole to make it difficult to analyze the flow of funds.

This strategy was also identified by investigators in Operation Hidden Carbon, which targeted the use of the fuel market to launder money from the Primeiro Comando da Capital (PCC). According to the Federal Revenue Service, the group targeted in Thursday’s massive operation maintains financial relationships with the companies and people investigated in this first operation.