The Democrats said that the agency’s deputy commissioner had made this statement in a briefing to House staff members earlier this month, citing a provision in the 60-year lease with the Trump Organization that prohibits it from being held by any federal government employee.

But shortly after the Democrats issued their letter on Wednesday, the agency said that it had not yet reached such a conclusion.

“We can make no definitive statement at this time about what would constitute a breach of the agreement, and to do so now would be premature,” a spokeswoman for the agency, Ashley Nash-Hahn, said in a statement.

A decision on this question, she added, will not likely come until Mr. Trump takes office.

The hotel project was conceived by Paulo Figueiredo Filho, a right-wing businessman who said that he gained Mr. Trump’s interest in managing the property by boasting of family ties: Mr. Figueiredo Filho is the grandson of João Figueiredo, the last military dictator in an authoritarian government that ran Brazil from 1964 to 1985.

Anselmo Henrique Cordeiro Lopes, a federal prosecutor in the capital, Brasília, opened the criminal inquiry in October, identifying $40 million in investments in the hotel made by two small Brazilian pension funds. One invests on behalf of retirees of a state-controlled information technology firm; the other manages the pensions for civil servants in Tocantins State.

In legal filings, Mr. Lopes said that he was examining why the two pension funds invested so much of their capital in the venture, positioning his inquiry within a broader federal investigation of graft at Brazil’s pension funds, pillars of the economy that have been involved in an array of scandals in recent years.

As part of the same investigation, Mr. Lopes is also focusing on the Trump Towers Rio, a project to build five futuristic office towers in downtown Rio that was announced in 2012 in conjunction with MRP, a Bulgarian real estate company. Unlike the Trump Hotel Rio, the partners in the downtown venture have not started construction.