ANJL says an abrupt betting ban in Brazil could push up to R$ 40 billion into the black market

The Associação Nacional de Jogos e Loterias (ANJL) is warning that a sudden shutdown of Brazil’s regulated sports betting market would hand more business to illegal operators and, by extension, to organized crime networks the US classifies as terrorist organizations. For PSPs, acquirers, and risk teams, the point is simple: if regulated channels disappear overnight, demand does not.

1. In a note released on Wednesday (23/9), ANJL said an abrupt ban on regulated sports betting in Brazil could strengthen criminal organizations that the United States has classified as terrorist groups. The association ties that warning to Tribunal de Contas da União (TCU) estimates that the illegal market already accounts for between 41% and 51% of all bets placed in the country, with the potential to move up to R$ 40 billion a year.
2. ANJL’s argument is a familiar one in high-risk payments: if licensed operators are shut down without a clear destination for existing demand, that spend does not vanish. It moves to unlicensed platforms outside tax collection and regulatory oversight, which the TCU has already flagged for money laundering, tax evasion, and match-fixing risks.
3. The association also framed the issue as a geopolitical one. According to ANJL, the US has intensified its offensive against Brazilian criminal organizations, and shifting tens of billions of reais from supervised rails into the clandestine market would strengthen Washington’s case for direct action against those groups.
4. There is also a capital-markets angle. ANJL said operators received state authorizations, invested money, hired staff, and built their businesses around an existing regulatory framework. A sudden reversal without a transition period, compliance deadline, or recognition of rights already granted would, in the association’s view, damage Brazil’s legal-risk profile for foreign investors.
5. The president of ANJL summed up the concern in the note, arguing that a rupture of this kind would not only strengthen the illegal market. The quote in the source is cut off, but the direction is clear enough: in this sector, regulatory whiplash is not just a policy issue, it is a payments-routing issue.

For payment providers serving betting, the practical takeaway is that the regulated share of volume is not just a compliance question. It is the difference between monitored flows, tax visibility, and underwriting discipline on one side, and offshore or illegal processing on the other.