With the recent enactment of the Brazilian Organized Crime Legal Framework (Law No. 15,358/2026, of 24 March 2026), Laws No. 13,756/2018 and 14,790/2023, which regulate fixed‑odds betting, have been amended to tighten supervision, strengthen anti‑money laundering measures, and curb the activity of unlicensed operators.
Although the main focus of the new framework falls on expanding the duties of financial institutions, there are at least three key aspects that require the immediate attention of fixed‑odds betting operators licensed to operate in Brazil. See below:
1. Advertising: The new item XII of Article 39 of Law No. 14,790/2023, due to its ambiguous wording, may be interpreted as a broad prohibition on any association with influencers, digital platforms, and even social media networks that also carry advertisements from irregular operators (i.e., those not licensed by SPA/MF). This reading is reinforced by the new item III of article 40, which prohibits “indirect” advertising of irregular operators. In this context, operators are advised to adopt contractual and due diligence measures to avoid engaging agencies, affiliates, or influencers that also promote – or have recently promoted – advertising for unlicensed betting operators. More broadly, it is advisable that all advertising content on social media and online clearly state that the operator is duly licensed, including the number and year of the ordinance granting the operating license.
2. Enhanced due diligence and expanded liability: The inclusion of articles 21‑A, 24‑A, and 24‑C, as well as new items in article 39 of Law No. 14,790/2023, has imposed additional monitoring and prevention duties on financial institutions with respect to transactions involving irregular operators, and has expanded their liability for failures to comply with these obligations. The natural trend is that banks and payment institutions will increase scrutiny over transactions related to betting, which may translate into additional bureaucracy, documentation requirements, and more intense monitoring of financial flows. For duly licensed fixed‑odds betting operators, this means, in practice, higher regulatory costs and the need to align their internal compliance policies with the new expectations of the financial system.
3. Future regulation by the Central Bank: Article 24‑B, added to Law No. 14,790/2023, provides for future regulation by the Central Bank of specific mechanisms to prevent the use of banking infrastructure by irregular operators. Measures under consideration include transaction types exclusive to betting, linked to a positive registry of licensed operators, in addition to other filters and preventive mechanisms. In this scenario, fixed‑odds betting operators should closely monitor upcoming regulatory acts issued by the Central Bank and prepare to adapt their technological infrastructure, KYC/KYB processes, and banking relationships to the new requirements once they are defined.
In conclusion, the changes introduced by Law No. 15,358/2026 expose licensed operators to significant risks, including potential sanctions for advertising practices that may be indirectly or unintentionally linked to irregular operators, higher operating costs resulting from increased financial scrutiny, and regulatory uncertainty regarding forthcoming Central Bank rules. This combination of factors calls for immediate preventive action – including a review of advertising contracts, strengthening of compliance procedures, and proactive dialogue with financial institutions – as well as ongoing attention to future regulatory developments on the subject.
