Brazil sets 45-day clock for banks to flag and block illegal betting flows under SPA/MF No. 2.750

Brazil’s Ministry of Finance has turned the anti-illegal-betting framework into an operational checklist for banks, payment institutions, and payment scheme operators. The new rules matter for high-risk PSPs because they spell out the transaction patterns, recipient profiles, and intermediaries that compliance teams are now expected to catch, freeze, and report.

1. The Ministry of Finance published Portaria SPA/MF nº 2.750 on Monday (14/9), signed by Daniele Correa Cardoso, Secretary of Prizes and Betting, on 10 September 2026. The rule regulates financial enforcement against the illegal fixed-odds betting market and sets out how banks, payment institutions, and payment scheme operators must identify, block, and report transactions linked to operators without authorization.
2. The new portaria replaces Portaria SPA/MF nº 566, dated 20 March 2025, which covered the same topic in broader terms. It operationalizes Decreto nº 13.033, dated 19 June 2026, which created the “financial suffocation” tools against the irregular market, and also incorporates the joint tax liability introduced by Lei Complementar nº 224, dated 26 December 2025.
3. The most operational part is Article 5, which lists the red flags obliged institutions must monitor. Among them: repeated or clustered amounts in recurring ranges consistent with betting deposits; a high frequency of small or medium-value transfers over short intervals from different senders; Pix transaction descriptions containing terms such as “apostas,” “bônus,” “recarga,” “palpites,” “prêmios,” or betting-brand references; and frequent changes of Pix keys, QR Codes, or beneficiary accounts after blocks or relationship terminations.
4. The rule also treats as suspicious transfers to legal entities with virtual office, coworking, or residential addresses, as well as newly formed CNPJs receiving large volumes of fragmented transactions that do not match the declared business activity. Using gateways, intermediaries, or other mechanisms to hide the ultimate beneficiary or the purpose of the payment is also a warning sign.
5. Brazil’s SPA/MF also introduces the concept of a “pessoa intermediária” — any individual or legal entity that repeatedly moves funds for an irregular operator. In practice, that widens the net beyond the direct merchant and puts mule structures and payment service providers used to mask the final recipient squarely in scope. The selection and analysis procedures must be completed within 45 days from identification.