Regulatory Radar — Fixed-Odds Betting (Ed. #4)

Week of June 15–19, 2026

This week was defined by a tightening crackdown on the illegal market — and this time with the President leading the charge: a new decree authorizes the freezing of funds from unlicensed betting operations. The bill has also begun to reach beyond the operator, with payment providers, advertisers and game suppliers now on the front line of enforcement, while the regulator convened a broad coalition in Brasília around Responsible Gaming. Below are the points that deserve your attention.

Government moves to freeze illegal betting funds — and wants to channel them to public security

The week’s big announcement came from the Presidential Palace. The President signed a decree authorizing the government to preventively freeze the funds of betting houses operating without a license: when the Ministry of Finance and the Ministry of Justice identify evidence of illegality, banks will be notified to freeze the accounts tied to those operations and, subject to due process, the money may be channeled to the National Public Security Fund. According to the Ministry of Finance, roughly 50,000 illegal sites have already been blocked, 350 operators identified and 37 financial institutions are suspected of moving irregular funds. The measure relies on the so-called Anti-Organized Crime Law.

What this means: the fight against the illegal market has gained a powerful lever — freezing the money, not just taking down websites. For financial institutions, the pressure rises to quickly identify and freeze accounts linked to irregular operators. For licensed operators, there is a positive competitive angle: the financial squeeze should reduce predatory competition from the underground market. It is worth watching how the preventive freezing will be implemented in practice, particularly the balance with due process of law.

Finance Ministry holds payment providers and advertisers liable for illegal operators’ taxes

A concrete development — and already in force. A new ordinance from the Ministry of Finance, published in the Official Gazette this week, makes payment providers and advertisers jointly liable for the taxes owed by betting operators acting without a license. In other words: anyone who helps enable an illegal bet may be charged for the tax the unlicensed operator failed to pay.

For financial and payment institutions, liability comes with a trigger. The SPA (the betting regulator) and the Federal Revenue Service will issue a joint notice identifying the irregular operator — with its corporate tax ID, the transaction and the account used — and the payment provider will have 24 hours to take measures preventing further transactions with that operator. If it fails to act, it becomes liable, alongside the operator, for the taxes due.

For advertisers, the standard is even tougher: liability applies regardless of any prior notice. Anyone advertising an unlicensed operator is automatically swept into joint tax liability — with no notice and no deadline. The charge will be formalized through an administrative proceeding, with the right to a defense and to contest it.

What this means: the government has turned the fight against the illegal market into a pocketbook problem for the entire chain — payments and advertising, not just the operator. For fintechs and payment institutions, the critical point is the 24-hour deadline: they need, from now on, an internal workflow ready to receive the joint notice and block transactions the same day. For agencies, influencers, affiliates and media outlets, the message is direct: advertising an unlicensed operator now carries automatic tax risk — it is worth checking any house’s license before closing an advertising or sponsorship deal. Combined with the bills moving through Congress on payments and taxation, the squeeze on the sector’s infrastructure layer is clear.

Game suppliers come into the enforcement crosshairs

A development this week raises a flag for those who supply games to the regulated market. The Public Prosecutor’s Office opened an investigation into a foreign studio that supplies a highly popular “crash”-type game, on suspicion that the very same game certified for licensed houses was also being offered by underground operators. The measure was published in the Official Gazette this week.

In the prosecutor’s view, by supplying the legal and illegal markets at the same time, the supplier would be leveraging its own technical certification to lend visibility and an appearance of legitimacy to unlicensed offerings — without paying taxes and without anti-money-laundering or responsible-gaming controls. The investigation also points to signs of misleading advertising, such as a gap between the advertised return to player (RTP) and the rate actually applied, and of bonuses with rules that breach SPA/MF norms. This is an ongoing investigation based on a preliminary inquiry — there is, for now, no decision on the merits.

The most sensitive aspect is the precautionary measures requested. The Public Prosecutor’s Office recommended that the SPA/MF immediately suspend the certification of the supplier’s games — and block the title even at licensed houses — until the company proves it has stopped supplying illegal operators and has implemented adequate controls. It asked Anatel (the telecoms regulator) to take down the links and domains tied to the game. The agencies have 48 hours to report initial measures and ten business days for a conclusive response; if the administrative route falls short, the Public Prosecutor’s Office signals it will turn to the courts.

What this means: liability is starting to move up the chain — from the operator to the game supplier — and the lever is certification. If the recommendation prevails, a studio could have a popular game suspended across the entire legal market because of its use in the illegal one. Suppliers and aggregators should review, right away, whom they license their games to, the exclusivity and anti-piracy clauses in their contracts, and their governance of RTP, bonuses and AML. For licensed operators, this is a continuity risk: it is worth mapping dependence on third-party games and having a plan B for titles under regulatory risk.

SPA seminar puts the consumer and responsible gaming center stage — and brings the justice system closer

The Secretariat of Prizes and Betting (SPA) held, in Brasília, its first major seminar dedicated to responsible gaming and the protection of the betting consumer. The event brought together, on the same stage, the betting regulator, the National Consumer Secretariat, consumer-protection agencies (Procons), Public Prosecutors’ and Public Defenders’ Offices, addiction-treatment specialists and CONAR (the advertising self-regulation body). The agenda covered over-indebtedness, the prevention and treatment of gambling disorder, and the challenges of advertising on social media.

The seminar also produced a concrete result: during the event, the Ministry of Finance and the Ministry of Justice signed a three-year technical cooperation agreement, joining the SPA and the Ministry of Justice’s digital-rights division for the exchange of information, studies and joint guidelines on betting, user protection and risk prevention in the digital environment.

What this means: the regulator is assembling an enforcement coalition that reaches well beyond the SPA — consumer protection, Public Prosecutors, Public Defenders, public health and, now, digital rights. For operators, the message is that the supervisory agenda will revolve around responsible gaming, over-indebtedness and advertising (with a magnifying glass on social media), and will be pressed on several fronts at once. It is worth aligning responsible-gaming and advertising policies now with what these bodies have been signaling — that is where guidance, enforcement actions and, eventually, new rules are likely to come from.

Advertising and payments take center stage: Congress and the Supreme Court advance

Advertising and payments have become the major regulatory targets — on several fronts at once. In the Chamber of Deputies, a cluster of bills restricting or banning sector advertising gained traction: two of them were consolidated into a single legislative track this week and a new bill, introduced a few days ago, proposes banning commercial advertising of betting. Another bill is advancing that would require banks and payment institutions to create filters to block transactions with irregular operators — already with a rapporteur appointed and an amendment window open. In the Senate, lawmakers called for the Finance Minister and the head of the SPA to appear and provide clarifications. And, in the judiciary, the Rio Grande do Sul state law restricting sector advertising awaits a priority ruling at the Federal Supreme Court (STF), with a suspension request filed by the Solicitor General’s Office (AGU).

What this means: the Executive, Congress and the states are pulling in the same direction — more advertising restrictions and more control over payments. None of the bills is law yet, but the convergence signals the direction of travel. For those who advertise or sponsor, it is worth reviewing media strategy now; for the payments chain, the point to watch is the potential blocking obligation. The final word on the states’ authority to legislate will rest with the STF.

Consumer litigation against operators is on the rise in the courts

This week’s court monitoring confirms a pattern: claims by bettors against licensed operators, mostly in Small Claims Courts, involving seven monitored houses. The two dominant strands are consumer damages claims and disputes over withheld winnings, with mixed outcomes — one large operator upheld a dismissal in São Paulo (the bettor failed to prove the claimed credit) and another was ordered to pay damages in Ceará. The gambling-disorder argument is also gaining ground, with bettors in treatment seeking to annul their bets.

What this means: consumer litigation is no longer occasional and has become routine for those operating in the retail segment. Technical evidence matters: operators with robust data trails (bet and transaction records) have been able to defeat claims. It is worth reviewing evidence-retention policies, customer-service workflows and, above all, responsible-gaming controls, which are at the heart of the gambling-disorder claims.

The week ahead

• Suppliers (B2B): on June 25 and 26, the SPA will hold the public hearing on the recognition of technology and service suppliers to operators — the step that precedes the B2B sector ordinance. It is the window to contribute before the rules are issued; suppliers and operators should follow it closely.
• Game suppliers: the deadlines set by the Public Prosecutor’s Office (48 hours for initial measures and ten business days for a response) on the certification suspension are running — worth watching the response from the SPA/MF and Anatel.
• STF: watch for a possible ruling on the request to suspend the Rio Grande do Sul advertising law, which is on a priority track.
• Payments: with the new ordinance in force, fintechs and banks should already have a 24-hour blocking workflow ready following the joint notice.

Our team is available to discuss the impact of any of these topics on your business.

This material is for informational purposes only and does not constitute legal advice. The analyses reflect the team’s understanding as of the publication date and may be revised in light of regulatory or case-law developments. For specific guidance on particular situations, please consult a member of our team. © Souto, Correa Advogados — Betting Regulation Practice.