Key Takeaways
- Brazil’s betting regulator, the Secretariat of Prizes and Betting inside the Ministry of Finance, published Ordinance SPA/MF No. 2,750 on 14 September 2026, which gives banks and payment institutions 24 hours to block an account the regulator flags and 48 hours to confirm the block.
- The warning indicators in Article 5 of the ordinance describe ordinary betting deposits rather than fraud, so a licensed operator paid through a gateway that hides the final recipient can look like the thing a Brazilian bank has just been told to stop.
- Poland, Norway and the Netherlands are building the same enforcement route through the payment system, so the question for a licensed operator in any of those markets is whether its receiving entities match the regulator’s published list of licensees automatically.
What does Brazil’s new payment ordinance require?
It requires banks and payment institutions in Brazil to find, report and stop payments going to betting operators that do not hold a Brazilian licence, and it puts a short clock on each step. The Secretariat of Prizes and Betting, usually shortened to SPA, issues a formal finding of irregularity, notifies financial institutions through a secure electronic system, and tells Banco Central do Brasil at the same time so the central bank can see what is moving across the system.1 The institution then has 24 hours to block the account and refuse new transactions and 48 hours to confirm it has done so, while a bank that spots the pattern by itself has to report to the SPA by the next working day and finish its own analysis within 45 days.2
It replaced an earlier ordinance, Portaria SPA/MF No. 566/2025, and extends to intermediaries, meaning anyone who repeatedly moves money on behalf of an unlicensed site. A bank that reports in good faith carries no civil or administrative liability for reporting, and the papers go to Brazil’s national public security secretariat so the money can be forfeited to the state.1,2 Some of the operational detail is still to come in an implementing instruction, and institutions get 30 days to adapt their systems once it is published.2
Why does this matter to a licensed operator and not just an illegal one?
It matters because the indicator list in Article 5 describes betting rather than crime. A bank is told to watch for repeated amounts falling in ranges typical of betting deposits, bursts of small and medium transfers arriving from many different senders in a short window, Pix transfer notes carrying words such as “apostas”, “bônus” or “recarga” (Pix is Brazil’s instant bank transfer system, and it carries most deposits), a payee that changes its Pix key or QR code shortly after a block, a recently registered company taking large scattered volumes that do not match the business it says it is in, and payments routed through gateways or intermediaries that make the final recipient hard to see.
A licensed operator produces most of that on a normal Saturday afternoon.
Inside a bank’s monitoring system, what separates a licensed operator from an unlicensed one is whether the receiving entity resolves to the SPA’s published list of authorised operators, which the SPA offers as a download and through an API so the check can run automatically.2 Where deposits arrive into an aggregator’s account, a recently incorporated subsidiary, or a payment partner registered at a serviced office, that check does not resolve and somebody has to make a judgement in a hurry. There is no hearing before a block, the bank has a day to act, and it is protected if it reported honestly, so the cost of caution sits with the operator. Federal betting tax receipts alone came to roughly R$7.3bn in the first half of 2026 and are expected to pass R$10bn across the year, which gives some idea of what a day of declined deposits is worth.3
Which other markets are enforcing through the payment system?
Poland, Norway and the Netherlands are doing versions of the same thing, and they differ mainly in who carries the duty.
| Market | Who blocks the payment | What triggers a block | Status |
| Brazil | Banks and payment institutions, on SPA notification | An SPA finding of irregularity, plus the Article 5 indicator list | Ordinance published 14 September 2026 |
| Poland | BLIK, the dominant mobile payment scheme | Transaction domain matched against the Finance Ministry register of illegal gambling domains, over 55,000 entries and about 700 added a month | Announced 1 September 2026, a voluntary measure |
| Norway | Banks, under section 5 of the Gambling Act | Any payment to or from an operator without a Norwegian licence | Ban long-standing; Lotteritilsynet opened its first formal inspection of nine banks in 2023 |
| Netherlands | Banks and payment firms, working alongside the KSA | Cooperation with the regulator rather than a statutory order | MPs pressed for formal powers over payment providers on 8 September 2026 |
BLIK decided on its own to check transaction domains against the Ministry of Finance register and decline anything that matches, which is a scheme rule rather than a law, and with 2.9 billion transactions worth PLN 441.5bn in 2025 behind it that does more work in Poland than most enforcement notices.4 Norway legislated years ago and has been slow to inspect, while Dutch MPs are still arguing about whether the KSA should hold the power at all, with channelisation to licensed sites now put below 50%.5,6
Whether any of this shrinks the illegal market is a different question, and nobody has shown that it does yet. Enforcement has moved from the operator’s website to the payment message, and that part is already settled.
What should operators do before the implementing instruction is published?
Reconcile the payment chain against the licence, entity by entity, in every market that has a payment-blocking regime. Thirty days is not long to correct a mismatch that has been sitting in a bank’s records for two years, and the work is the same whether the trigger turns out to be Brazilian, Polish or Dutch.
1. List every legal entity that touches player money in each market: the licensed company, any subsidiary, every PSP, aggregator and gateway, and the accounts deposits actually settle into.
2. Check each one against the regulator’s published list of licensees, using the reference a bank would use, and write down every place a company name, registration number or trading name fails to match.
3. Correct the mismatches, and where a payment partner’s own profile reads badly against the indicator list, a new registration or a serviced office address for instance, get the explanation on file before anyone asks for it.
4. Agree the escalation route now: who you call at the bank, who you call at the regulator, what evidence shows the block was wrong, and how many days you can trade with one deposit route switched off.
Boardroom Questions
1. Can we show today that every account our player deposits settle into resolves to our licensed entity on the regulator’s own published list, in each market where we hold a licence?
2. Which of our payment partners would read badly against Brazil’s Article 5 indicators if a bank compliance team opened their file cold, and what is our answer for each one?
3. If a bank froze our main deposit account tomorrow morning with no warning, who owns the response, how long would it take us to get the block lifted, and what does each day of that cost?
Sources
1. Agência Gov (Brazilian Government news agency), ‘Portaria fortalece o enfrentamento ao mercado ilegal de apostas’, September 2026, https://agenciagov.ebc.com.br/noticias/202609/spa-publica-portaria-de-enfrentamento-ao-mercado-ilegal-de-apostas
2. BNLData, ‘SPA-MF detalha combate a apostas ilegais e estabelece asfixia financeira’, 15 September 2026, https://bnldata.com.br/spa-mf-detalha-combate-a-apostas-ilegais-e-estabelece-asfixia-financeira/
3. SBC News, ‘Brazil tightens bank controls on illegal gambling flows’, 16 September 2026, https://sbcnews.co.uk/igaming/2026/09/16/brazil-flows-payments/
4. Focus Gaming News, ‘Payment provider BLIK to block illegal gambling transactions in Poland’, September 2026, https://focusgn.com/payment-provider-blik-to-block-illegal-gambling-transactions-in-poland
5. iGaming Business, ‘Norway regulator monitors banks over illegal gambling transactions’, https://igamingbusiness.com/tech-innovation/payments/norway-monitors-banks-illegal-gambling/
6. Yogonet International, ‘Dutch lawmakers demand tougher illegal gambling enforcement’, 8 September 2026, https://www.yogonet.com/international/news/2026/09/08/126288-dutch-lawmakers-demand-tougher-illegal-gambling-enforcement
7. Ministério da Fazenda, Secretaria de Prêmios e Apostas, legislation index for fixed-odds betting, https://www.gov.br/fazenda/pt-br/composicao/orgaos/secretaria-de-premios-e-apostas/apostas-de-quota-fixa/legislacao