Betting Market

The regulation of the blocking of accounts and funds linked to irregular fixed-odds betting operators represents a new stage in the consolidation of the regulated betting market in Brazil. With the enactment of Decree No. 13,033/2026, the Federal Government now has a specific procedure to interrupt financial flows associated with the irregular operation of the activity, shifting oversight to the most sensitive point of these operations: the movement of funds.

Until now, much of the fight against illegal betting has focused on removing websites, apps, domains, and advertising channels without federal authorization. While relevant, this type of measure has limited reach given the speed at which new digital structures can be created. The decree advances precisely by targeting the economic infrastructure that allows the irregular business to continue: without access to accounts, payment methods, and financial transactions, the clandestine operation loses its capacity for scale and permanence in the market.

Operational Flow and Identification of Irregularities

The regulation governs Article 21-A of Law No. 14,790/2023 and establishes an operational flow involving the Secretariat of Prizes and Bets of the Ministry of Finance, financial and payment institutions, payment arrangement providers, the Central Bank, the National Secretariat of Public Security, and the Attorney General's Office. If irregular operation of fixed-odds betting lotteries is found, precautionary measures may be adopted to block accounts and prevent new transactions, without prejudice to due process, the right to a full defense, and the need for a court decision for the definitive forfeiture of the funds.

The decree defines an irregular operator as any natural or legal person who directly or indirectly operates fixed-odds betting without authorization. The irregularity may be verified by the Prizes and Betting Secretariat itself, through a substantiated complaint from third parties, or based on evidence of electronic fraud. Once sufficient evidence is identified, a report will be issued describing the facts, identifying the operator, the means used, the institutions involved, the transactions identified, and the legal basis for the blocking.

Deadlines for Compliance and Allocation of Funds

After the issuance of the official notice, the obligated institutions must block, within 24 hours, the accounts held by the identified irregular operators and prevent the movement of funds held in them. They must also adopt measures to prevent new transactions intended to enable, directly or indirectly, the illegal operation of betting. Within 48 hours, they must report compliance with the measure, indicating blocked accounts, balances, accounts not located or closed, and any operational difficulties.

A central point of the decree is the distinction between precautionary blocking and definitive forfeiture of assets. Administrative blocking does not constitute a final sanction; it is preventive in nature and seeks to preserve resources while the irregularity is investigated. Once the blocking is confirmed, the case will be forwarded to the National Secretariat of Public Security, responsible for conducting the preparatory administrative process for forfeiture, with the possibility of defense by the interested party. Definitive forfeiture will depend on legal action filed by the Attorney General's Office.

Another relevant aspect is the destination of any assets declared forfeited. The decree stipulates that, following a court decision, the funds may be transferred to the National Public Security Fund, bringing the fight against illegal betting closer to a broader policy of confronting illicit economic structures, especially when there is evidence of money laundering, fraud, criminal association, or other related offenses.

Impacts on the Regulated Market and Compliance Challenges

For properly authorized operators, the measure tends to be seen as a step forward in protecting the regulated market. The continued existence of illegal betting creates significant competitive asymmetry, since authorized operators are subject to licensing requirements, integrity controls, advertising rules, anti-money laundering measures, responsible gaming mechanisms, tax obligations, and ongoing oversight. By hindering the financial transactions of unauthorized companies, the regulation helps reduce unfair competition and reinforce the separation between the regulated and illegal markets.

The most immediate effects fall on financial institutions, payment institutions, and payment arrangement providers. These agents will occupy a central position in the execution of blocking measures, as they will be responsible for identifying accounts related to notified irregular operators, preventing transactions, and reporting information to the Prizes and Betting Secretariat. This will require a review of internal routines, the ability to respond within short timeframes, and integration between areas of compliance, anti-money laundering, legal, technology, risk, and relations with authorities.

Despite the regulatory progress, the practical application of the decree is likely to generate significant debate. The Administration will need to clearly demonstrate the connection between the blocked accounts and the illegal operation of betting, especially since the blocking could affect significant amounts and complex legal relationships. It will also be necessary to ensure the protection of bona fide third parties, including bettors with outstanding payments, service providers, and business partners who did not participate in the irregularity.

Regulatory Inflection and Legal Certainty

Decree No. 13,033/2026 should be understood as part of a turning point in the regulation of betting in Brazil. Having overcome the initial stage of market structuring, marked by authorizations, operational rules, and the blocking of unauthorized websites, state action is now reaching the financial infrastructure that sustains the activity. The effectiveness of the regulation will depend, however, on the quality of its implementation: well-founded inspection reports, clear guidelines for obligated institutions, and complementary regulations capable of providing operational security for compliance with the measures.

In this context, the decree is not limited to expanding the instruments for suppressing illegal operations. It reinforces the institutional consolidation of the regulated market itself, seeking to separate, more effectively, authorized operators from clandestine structures. In a digital, transactional, and rapidly adapting sector, combating illegality requires more than taking platforms offline; it requires interrupting the financial flows that enable irregular activity. The challenge, from now on, will be to ensure that the repression of irregular operations is accompanied by predictability, institutional cooperation, and legal certainty for agents acting in accordance with the regulations.

Article written by: Leonardo Neri and Nicoly Crepaldi.

• “Decree No. 13.033/2026 shifts the oversight of illegal betting from the digital environment to the financial infrastructure that supports these operations.”
• “The distinction between precautionary asset freezes and definitive forfeiture of assets will be essential to balancing regulatory effectiveness, due process, and legal certainty.”
• “For authorized operators, the decree represents progress in protecting the regulated market, addressing one of the main sources of competitive asymmetry: the operation of clandestine platforms without the same costs and regulatory obligations.”
• “Financial and payment institutions will play a central role in the execution of regulatory policy, which will require a review of internal processes, integration between compliance areas, and the ability to respond within shorter timeframes.”
• “The regulatory challenge will be to ensure that the crackdown on illegal operations goes hand in hand with predictability, institutional cooperation, and the protection of bona fide third parties.”
• “Combating illegal betting requires a more sophisticated approach: it's not enough to take platforms offline; it's necessary to target the economic flows that make the continued existence of these operations viable in the market.”

References:

• BRAZIL. Decree No. 13,033, of June 19, 2026. Regulates article 21-A of Law No. 14,790, of December 29, 2023, to provide for the operational procedures for blocking accounts. Brasília, DF: Presidency of the Republic, 2026.
• BRAZIL. Civil House. The Federal Government regulates the blocking of funds from illegal betting operations and strengthens the fight against irregular operations.. Gov.br, Brasilia, DF, June 19, 2026.