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Involvement of international operators

Engaging international operators in Brazil

1) Why Brazil is now

The online betting and gaming market in Brazil has moved to full regulation: at the end of 2023, Lei 14 was adopted. 790/2023 (law "on fixed odds rates"), and in 2024-2025, the Ministry of Finance, through Secretaria de Prêmios e Apostas (SPA), issued a portary package and opened administrative authorization procedures. This created predictable entry rules for international brands.

In addition, the regulator shows the real progress of "whitewashing": according to the results of the 1st half of 2025, SPA reported on 17.7 million Brazilians who made bets in the legal circuit, and 15 + thousand blocked illegal sites. This confirms the flow of demand into the licensed sector - an important signal for investors.


2) Basic entry requirements: legal construction

In Brazil, the operator can only be a local legal entity operating under Brazilian law, with a location and management in the country (in the form of Ltda or S.A.). A subsidiary of a foreign group is allowed, but certainly Brazilian by incorporation.

The key condition is at least 20% of the capital of the Brazilian co-owner (individual or legal entity). This directly follows from the law and is explained by law firms accompanying the admission of operators.

What does this mean in practice for a foreign brand:
  • Establish a Brazilian subsidiary (Ltda/S. A.) with ≥20% local share;
  • Locate head office and management in Brazil;
  • Pass SPA authorization as an "agent-operator."

3) Licensing: Portaria SPA/MF nº 827/2024

The procedure and conditions for obtaining authorization are established by Portaria 827/2024. Compliance with five blocks of criteria is required: legal capacity, fiscal/labor regularity, integrity, economic and financial solvency, technical qualifications.

Economic parameters from practical reviews on Portaria 827/2024: outorga (one-time fee) up to R $30 million for 5 years with the right to use up to three brands on one legal entity.


4) Payment loop: only via BCB and PIX (crypto prohibited)

SPA separately regulated payments: Portaria 615/2024 requires all transactions to go through institutions authorized by the Central Bank (BCB). Cash, boletos, credit cards and crypto assets are prohibited in the licensed segment; PIX, TED, debit/prepaid cards through authorized providers are allowed.

Conclusion: for an international operator, local payment integrations with PIX and Brazilian providers are mandatory - this is critical for both conversion growth and compliance.


5) Advertising and branding: new restrictions

Since 2024, the SPA portarium on advertising liability and responsible gambling has been operating (including requirements for warnings, bans on "abusiva publicidade"). Additionally, the Senate on May 28, 2025 approved PL 2. 985/2023 with strict restrictions on advertising with the participation of athletes, artists, influencers (the project went to the Chamber). This changes the sponsorship and KOL marketing models familiar to international brands.


6) Enforcement and perimeter protection

The state has strengthened the blocking of illegal sites (Anatel), and SPA notifies and fines the financial sector for working with unauthorized sites. For international groups, this means: working "in white" is not only more profitable (traffic shifts), but also safer in terms of payment risks.


7) Data and privacy: LGPD

Any work with player data must comply with the LGPD (Lei 13. 709/2018) and ANPD supervision: the law regulates the processing of personal data, including digital transactions, and is mandatory for operators, their processors and affiliated marketing partners.


8) Market entry models for international operators

A. "Net" Subsidiary:
  • Creation of Brazilian Ltda/S. A. with a local partner of ≥20%;
  • Bet on own brand (up to 3 marks per license).
B. JV/Local Player Partnership:
  • Quick access to PIX infrastructure, local marketing and SPA requirements;
  • Risk division and CAPEX/outorga.
C. M & A/entry into local media or club ecosystems (taking into account advertising restrictions on influencers and athletes):
  • Shift the budget from personal endorsements to content partnerships, responsible gambling, MICE/community initiatives.

9) Practical roadmap (12-18 months)

1. Structure and participation

Select form Ltda/S. A., arrange a Brazilian legal entity with management in the country; confirm ≥20% of Brazilian share (physical/legal entity).

2. Pre-audit and authorization dossier

Collect packages for 5 blocks (legal, fiscal/labor, integrity, financial independence, technical qualification); Prepare RG/AML/KYC platform and policy certification.

3. Payments and Finance

Integrate PIX/TED through BCB-authorized providers; exclude prohibited methods (crypto, boletos, credit cards in Portaria 615/2024 logic).

4. Marketing and Brand Safety

Comply with advertising portariums and RG; adapt the strategy to a potential ban on athletes/influencers (PL 2. 985/2023).

5. Data & Trust

Lead processes to LGPD, assign DPO/Encarregado, build DPIA and processing contracts with providers/affiliates.

6. Anti-offshore hygiene

Hard cut off gray payment channels and mirrors; monitor Anatel/SPA block lists so as not to lose access/payments due to the fault of partners.


10) Frequent questions from international groups

Will we be able to enter without a local shareholder?

No: ≥20% of the Brazilian share in the operator's capital is required.

Is it possible to leave a payment in a crypt for VIP?

No: for licensed brands, crypto assets are prohibited; Use PIX/TED/Debit/Prepaid Cards via BCB participants.

How many brands can you run on one license?

According to law enforcement practice for Portaria 827/2024 - up to 3 trademarks per legal entity.

Do I need to transfer data to Brazil?

LGPD allows cross-border transfers subject to conditions (legal grounds/guarantees), however, for speed and trust, it is better to build a local data perimeter and clearly formalize processing agreements.


11) What Brazil will get from the arrival of international operators

Investments and taxes through outorga and transparent GGR;
  • Employment in compliance, payment infrastructure, technical support and marketing;
  • Raising RG/AML/KYC standards and protecting the consumer;

Integration with the PIX economy and fintech ecosystem of Brazil.


Brazil has become a regulated but demanding market: international brands here need a Brazilian legal platform (with a local share of ≥20%), SPA authorization for Portaria 827/2024, strict payment compliance (PIX/BCB, without crypto), LGPD compliance and new advertising discipline. In exchange, the market opens up access to a large-scale audience, PIX infrastructure and a growing "white" ecosystem - with real perimeter protection from offshore.

Key sources: Law 14. 790/2023 (Planalto); SPA/Ministry of Finance portal and "Apostas de Quota Fixa" section; Portaria 827/2024 (terms of authorization) and 615/2024 (payments); SPA and Anatel news on lockdowns; LGPD materials.

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