Deadline Alert – Annual Compliance Report to SPA/MF – Only two months left
As the end of the year approaches, please note that there are only two months left to submit the Annual Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Compliance Report to the Secretariat of Prizes and Betting (SPA/MF), as established in Article 11 of SPA/MF Ordinance No. 1,143 (February 1, 2026).
Considering the complexity and volume of information required, we recommend starting the data consolidation process as soon as possible to avoid delays and, consequently, non-compliance with this obligation.
Please note that the required document is not a simplified report, but a technical and comprehensive Annual Report that demonstrates the effectiveness of the policies, procedures, and controls implemented throughout 2025, in compliance with regulatory obligations and anti-money laundering measures established by SPA/MF.
The report should address, for example:
- • Transaction Analysis and Monitoring: Demonstration of the application of monitoring rules and filters, including metrics on the detection of suspicious patterns.
- • COAF Alert Metrics: Details on the volume of Suspicious Transaction Reports (STRs) submitted and the compliance of internal procedures.
- • Compliance with KYC/KYB/KYP Controls: Evidence of diligence in identifying and verifying players, partners, and employees, including the application of enhanced, risk-based due diligence processes.
- • Risk and Control Structure: Presentation of internal risk assessments and action plans implemented to mitigate vulnerabilities.
Compliance with this obligation is essential to confirm to the regulatory authority the Operator’s commitment to regulatory compliance and its efforts throughout 2025 to contribute to building an ethical and sustainable sector.
The Compliance team at Souto Correa Advogados is available to provide technical support for structuring, gap identification, and drafting and/or reviewing the Report, ensuring that the document fully meets SPA/MF requirements.