Contrarian Corpus
short seller research note initial thesis
2022-11-16 · 47 pages

DLocal Ltd. DLO

Muddy Waters is short DLO: contradictory TPV disclosures, implausibly high FX-driven take rates, governance failures and ~$1bn of insider selling point to likely fraud at the Uruguay-based payments processor.

N 4 Narrative
V 2 Visual
C 2 Craft
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Thesis

Muddy Waters is short DLocal (NASDAQ: DLO), the Uruguay-based cross-border payments processor spun out of AstroPay, arguing the company is likely a fraud. DLO's filings contain materially contradictory TPV and receivables disclosures — the 2019 New Merchant cohort was reported as both $471 million and $56 million — which Muddy Waters frames as classic cooked-books evidence. DLO's take rate is multiples of peers like Ebanx, Adyen, and PagSeguro, with roughly half driven by FX gains that should be closer to 150bps than the ~290bps booked. Governance is riddled with red flags: a fintech running on Excel, repeated Malta Tier 1 capital breaches, questionable auditors, AstroPay entanglements, and a $38.7mm PrimeiroPay 'prepayment' that enabled insider option exercises. Management and directors dumped ~$1 billion in stock within five months of the IPO, and five senior executives have resigned since June 2022.

SCQA

Situation

DLocal is a fast-growing Uruguay-based cross-border payment processor spun out of AstroPay, serving merchants like Google in Latin America and emerging markets at a reported take rate that makes it a peer-group outlier.

Complication

Public filings contradict themselves on TPV and receivables, the take rate is 2-3x peers with implausible FX gains, governance is thin (Excel-run ops, Malta capital breaches, AstroPay entanglements), and insiders have dumped ~$1 billion.

Resolution

Short DLO; the accounting contradictions, outlier unit economics, and insider flight indicate likely fraud and materially overstated revenues rather than a legitimate outlier business.

Reward

Muddy Waters does not publish an explicit price target but frames DLO's $6.3bn market cap at $21.22 as built on overstated revenues, implying material downside as the fraud narrative emerges.

The three reasons

  1. 1

    Contradictory TPV and receivables disclosures suggest cooked books

  2. 2

    Take rate is 2-3x peers with implausibly large FX gains

  3. 3

    Governance red flags and ~$1bn of insider selling post-IPO

KPIs cited

Gross Take Rate
DLO 4.04% in 2021 vs Ebanx 1.16%, Adyen 0.20%, PagSeguro 2.75%
Net Take Rate
DLO 2.16% in 2021, multiples of peers' 0.23%-0.46%
FX contribution to take rate
~290bps in 2020 vs MW estimate of ~150bps or lower
2019 cohort TPV variance
Reported as both $471mm and $56mm — 741% variance between filings
2020 cohort TPV variance
Reported as both $343mm and $260mm — 32% variance
Insider selling
~$1 billion in stock sold by insiders in first 5 months post-IPO
Client funds reconciliation deficit
$3.3mm deficit at DLO, $4.1mm deficit at Malta Operating subsidiary
Malta Tier 1 capital
Breached capital requirement two years in a row
Senior executive resignations
5+ high-level departures in 5 months since June 2022
Market cap / price
$6.3bn market cap at $21.22 share price on Nov 16, 2022

Pattern membership

Where this document fits across the library's 12 rhetorical / structural patterns.

Notable slides (6)

Notes

Memo-style short report (Word-document formatting, blue section headers, tables and embedded screenshots — no slides). Opens with a Theranos allusion ('no pictures of its CEO wearing black turtlenecks'). Title borrows a Twain-attributed quote: 'History Never Repeats Itself, but it Does Often Rhyme.' Classic Muddy Waters fraud-pattern stack: accounting contradictions + take-rate outlier + governance red flags + insider selling + exec exodus. Carson Block credited as Director of Research on the cover. No explicit price target, consistent with MW's usual practice.