MED 2.0 in practice: the first operational effects are already showing up in Pix processing

Weeks after it took effect, the new Pix Special Refund Mechanism, MED 2.0, has stopped being a regulatory abstraction and become an operational daily grind. For high-volume Pix processors, especially in iGaming, the issue is no longer theory: notifications arrive, balances get blocked, and DICT marking starts to affect the business.

1. The response window is now part of the daily workflow. The volume of Notificações de Infração has increased, and each one requires analysis, a decision, and a reply within a tight deadline. If the process still depends on spreadsheets and email between teams, the window closes before the response is out. What used to be a periodic risk-team task has become an everyday operational requirement.
2. Balance freezes are hitting cash flow. Once an infraction is accepted somewhere in the chain, the corresponding balance is blocked, even if the money has already moved through the operation and was shown as available. For businesses with daily settlement and tight margins, that affects player withdrawals, payouts, and cash cycle predictability. The chain can also trigger new blocks after a request has already been closed, which means monitoring cannot stop at the first alert.
3. DICT marking now carries business consequences. Accounts involved in fraud chains receive a mark in DICT, and that mark follows the operation’s reputation whether or not funds were eventually returned. It does not show up on the day’s statement, but it does show up in conversations with banking partners and in regulator scrutiny, with concrete cost: tougher banking relationships, harder compliance, and worse settlement conditions.
4. The core issue is visibility, not company size. The article’s point is blunt: the difference is not how big the operation is, but how clearly it can see the origin and path of each transaction in real time. Operators that can trace flows quickly respond on time, anticipate freezes, and avoid becoming a marked link in the chain. Operators that wait for the notification pay for it in time, cash, and reputation.
5. Manual processes are no longer enough. With high volumes and short deadlines, spreadsheet-driven workflows are not practical. That is why the text points to Sentinela, Connect PSP’s compliance and antifraud engine, and its Advanced Transaction Tracking Module, which assigns each transaction a tracking layer for faster response and continuous monitoring.

For PSPs, acquirers, and banking partners exposed to high-volume Pix flows, the practical message is simple: MED 2.0 is no longer a policy update sitting on the shelf. It now affects response times, blocked funds, and the quality of banking relationships in day-to-day operations.