Payments and banking: Can we move player money?

Medida Provisória nº 1,394/2026 prohibits payments linked to fixed-odds betting as part of the same instrument that prohibits the underlying activity, advertising and sponsorship. This is not a standalone payments rule but a component of the general prohibition that took effect from the Measure's 25 September 2026 publication. No separate payment-corridor restriction, cross-border capital control, or payment-processor obligation beyond this general prohibition was evidenced.

MP 1.394/2026 requires a structured wind-down of payment flows tied to fixed-odds betting. Remaining player balances are being remitted to banks matched by CPF, with bank-processed returns scheduled for 9 to 14 October 2026, following a voluntary-withdrawal window for bettors that closed at 23:59 on 5 October 2026. Routine payment processing in support of fixed-odds betting is now prohibited nationwide; the only payment activity currently permitted in connection with the sector is this wind-down return process for balances held at the time the ban took effect.

The Secretaria de Premios e Apostas's portaria of 15 September 2026 expands procedures aimed at preventing, identifying and repressing payment transactions linked to irregular fixed-odds betting exploitation. This builds on an existing practice requiring banks to freeze unlicensed-operator accounts within 24 hours. With the entire fixed-odds betting sector now prohibited by Medida Provisoria 1.394/2026, this payment-interdiction architecture, previously targeted at the unlicensed segment specifically, now applies in practice across the whole formerly-licensed sector as well, since that sector has itself become unauthorised.

Lei 15.358/2026, which inserted new articles into Lei 14.790/2023, requires banks and payment institutions to freeze accounts belonging to unauthorised betting operators and to block new transactions with them, with any forfeited funds directed to the national public security fund. This represents a substantial expansion of the payments-enforcement architecture, converting what had previously been a domain-blocking and administrative-penalty regime into one that also operates through mandatory financial-institution action. This finding is reported by a single vendor-aggregator source citing the amending articles and has not been independently verified against Planalto's consolidated text this pass, but it is consistent with the broader enforcement-tightening pattern observed elsewhere in the regime this cycle.

Two new instruments materially expand financial-institution accessory-liability exposure in the betting sector this cycle. Decreto 13.033/2026 and Ministério da Fazenda Portaria 1.766/2026 create joint and several tax liability, under Complementary Law 224/2025 Article 6, for banks, payment institutions and payment arrangers that continue processing transactions for unauthorised betting operators after formal notification. This finding carries probable confidence and mixed durability — a decree and ministerial ordinance rather than primary statute — and reported compliance-window figures (variously 24 or 48 hours) were inconsistent across secondary sources and not reconciled this cycle. Separately, Lei 15.328/2026, the Anti-Faction Law, empowers immediate freezing of accounts and funds linked to unauthorised betting operations, framed as an organised-crime countermeasure; as primary legislation this power is durable, though Banco Central implementing norms on its execution mechanics were not independently confirmed against a primary source. Together these instruments mark a structural shift toward using the financial sector as a frontline enforcement lever against illegal betting flows, materially raising accessory-liability exposure for payment processors operating in or with the Brazilian market.