Brazil Tightens Sports Betting Rules: ANJL Reviews New Authorization Criteria

The Brazilian gambling landscape is undergoing a massive transformation as the January 1, 2025, launch date for the regulated market approaches. On Friday, May 31, the National Association of Gaming and Lotteries (ANJL) convened to discuss critical updates to the draft ordinance intended to replace SPA/MF Ordinance No. 827/2024. This meeting, attended by a significant number of members, served as a platform to evaluate technical contributions and prepare a collective industry response to the government's latest proposals.

According to the Ministry of Finance, the new requirements are built on three primary pillars. First, the government aims to strengthen documentation for preventing money laundering. Second, there is a push to accelerate the assessment of an operator's financial status and capital source. Finally, the proposal seeks to eliminate information asymmetries between regulators and operators through more detailed technical guidelines. The goal is to create a transparent and uniform licensing environment for all participants.

Numbers and facts

The scale of the Brazilian opportunity is immense. Reports from the International Betting Integrity Association (IBIA) suggest that sports betting turnover could reach 34 billion USD by 2028, with gross wins totaling approximately 2.8 billion USD. However, entering this market comes with a high price tag. A federal license costs 30 million Brazilian Real (BRL), roughly 5.5 million USD. This license is valid for five years and permits the operation of up to three distinct brands.

Despite these costs, interest is soaring. By the priority deadline of August 20, 2024, exactly 113 operators had submitted their license requests to the Secretariat of Prizes and Betting (SPA). The surge was particularly notable at the end of July, with 108 of the 113 applications arriving after the final ordinance on sanctions was published. Neil Montgomery of Montgomery & Associados noted that the SPA intends to provide feedback on application completeness within 35 days of submission.

Background

The ANJL legal team, including attorneys Hygo Carvalho, Pedro Prates, Rafael Fernandes, and Alice Ravazzoli, conducted a comprehensive study of the technical input provided by association members. They prioritized issues based on their criticality and potential impact on operations. ANJL President Plínio Lemos Jorge emphasized that a unified front is essential for the industry's success.

"We will discuss all of this together within the association. Together, we become stronger. One member’s challenge is everyone’s challenge. We will address issues that matter to the entire sector so that everyone can take part in this process." - Plínio Lemos Jorge, President of ANJL

Beyond the associations' efforts, strict operational rules are already set in stone. Law No. 14,790/2023 dictates that companies must be established in Brazil with at least 20% local capital. Furthermore, the use of '.bet.br' domains is mandatory, and payment methods are restricted to electronic transfers. Credit cards and cryptocurrencies are strictly prohibited to ensure better monitoring of financial flows.

Why it matters for German players

For players in Germany, the Brazilian regulation serves as a reminder of the importance of local licensing. While Brazil is just beginning its journey into a regulated framework, Germany established its modern legal market with the 2021 Interstate Treaty on Gambling (GlüStV 2021). German players benefit from one of the highest levels of protection worldwide, managed by the GGL (Gemeinsame Glücksspielbehörde der Länder). This includes the 1,000 EUR monthly deposit limit and the 1 EUR stake limit for virtual slots.

German residents should avoid operators licensed only in Brazil or other non-EU jurisdictions like Curacao. Only sites listed on the official GGL White-List provide legal certainty, guaranteed payouts, and integration with the national OASIS player blocking system. A Brazilian license offers no legal protection or recourse for a resident of Germany in the event of a dispute.

What it means for GGL-licensed casinos

German licensed operators, many of whom are global players like Betano, are keeping a close eye on South America. The high cost of entry in Brazil shows that regulation is becoming an expensive endeavor worldwide. GGL-licensed casinos already operate under high tax burdens and strict advertising rules. The professionalization of the Brazilian market might lead to a shift in global marketing budgets, but the German market remains a cornerstone of stability due to its mature legal framework. For operators, maintaining a GGL license remains the ultimate badge of integrity in the European market.