SPA-MF details the fight against illegal betting and establishes financial strangulation.
The Ministry of Finance published, this Monday (September 14th), in the Official Gazette of the Union, Ordinance SPA/MF No. 2.750, signed by the Secretary of Prizes and Bets, Daniele Correa Cardoso, on September 10, 2026. The regulation governs the financial fight against the illegal fixed-odds betting market, detailing how banks, payment institutions, and payment arrangement providers should identify, block, and report transactions linked to unauthorized operators. The ordinance revokes Ordinance SPA/MF No. 566, of March 20, 2025, which dealt with the same subject in a more generic way.
The measure operationalizes Decree No. 13.033, of June 19, 2026, which created the instruments of "financial asphyxiation" against the irregular market, and incorporates the joint tax liability introduced by Complementary Law No. 224, of December 26, 2025. Together, the two previous acts created the legal framework; the new ordinance defines the practical procedures that financial institutions must follow.
Mapping red flags for banking compliance
The most detailed part of the regulation is in Article 5, which lists the indicators of irregular exploitation that obligated institutions must monitor. In practice, this provision functions as a manual of alerts for the compliance departments of banks.
Among the mapped signals are: repeated or concentrated values in recurring ranges compatible with betting deposits; high frequency of small or medium value transfers in short intervals by different senders; Pix transaction descriptions containing terms such as "bets", "bonuses", "recharge", "guesses", "prizes" or suggestive brands of betting houses; and frequent replacement of Pix keys, QR Codes or recipient accounts soon after blocking or termination of the relationship.
The ordinance also establishes as evidence of irregularity transactions destined for legal entities with addresses in virtual offices, coworking spaces , or residential addresses, as well as recently constituted CNPJs (Brazilian taxpayer identification numbers) that begin to receive a large volume of fragmented transactions incompatible with the declared activity. The use of payment gateways , intermediaries, or other mechanisms to conceal the final beneficiary or the purpose of the transaction also constitutes a warning sign.
The regulation also introduces the concept of an "intermediary": any natural or legal person who repeatedly moves funds for the benefit of an irregular operator. This inclusion broadens the scope of the regulation beyond the direct operator, targeting shell companies and payment service providers used to mask the final recipient of the funds.
The timeframe for carrying out the selection and analysis procedures cannot exceed 45 days, starting from the identification of the suspicious situation.
Account blocked within 24 hours and loss of funds.
The operational flow foreseen in the ordinance begins with the identification of the irregularity by the Secretariat of Prizes and Bets (SPA-MF), which issues a report of irregularity, a document that also initiates the administrative process of forfeiture of the blocked funds in favor of the Union. The SPA-MF then notifies the financial institutions through a secure electronic system, simultaneously informing the Central Bank of Brazil for supervisory purposes.
Upon receiving the notification, the institutions have a maximum of 24 hours to block the accounts of the identified irregular operators and prevent further transactions. Confirmation of compliance with the measure must be sent to the SPA within 48 hours of the blocking. The case files and associated documents are then forwarded to the National Secretariat of Public Security of the Ministry of Justice and Public Security for the conduct of the forfeiture process.
The regulation also stipulates that, when attempting to carry out a transaction in favor of a person identified in the verification report, the client must be informed by the financial institution itself that the operation cannot be completed due to notification from the SPA (Special Purpose Entity).
Blocking notices may be accompanied by a communication of joint and several tax liability as provided for in Article 6 of Supplementary Law No. 224/2025 and regulated by Ministry of Finance Ordinance No. 1.766, of June 17, 2026 — which means that obligated institutions that proceed with irregular transactions may be jointly and severally liable for the taxes due.
Protection for the communicator and regulatory gap
To encourage proactive reporting, the ordinance establishes a protection mechanism: communication made in good faith does not entail civil or administrative liability for the reporter, according to article 7, paragraph 4. The measure creates a "safe haven" for banks and payment institutions that report indications to SPA-MF without definitive evidence of irregularity.
The regulatory coordination with the Central Bank is materialized in the citation of CMN Resolution No. 5.320, of June 25, 2026, which justifies the rejection of transactions by obligated institutions, indicating prior coordination between SPA-MF and the National Monetary Council in the design of the measure.
One point limiting the immediate effect of the regulation is the delegation of key operational aspects to a Normative Instruction that has not yet been published. The minimum data to be communicated, the layout of the communications, and the technical procedures for sending them depend on this supplementary act. Obligated institutions will have 30 days, from the publication of the normative instruction, to adapt their systems. Before that, institutions that do not communicate through the Central Bank's system have 30 days, from the publication of the ordinance, to inform the SPA of their institutional contact addresses. While the normative instruction is not issued, the practical effect of the ordinance remains partially suspended.
Ministry of Finance Ordinance SPA/MF No. 2.750, of September 10, 2026
