Registration of foreign operators (Curacao, Malta) - Brazil

Registration of foreign operators (Curacao, Malta) and Brazil

💡 Important: the text is informational. He does not call for circumventing local laws and does not give instructions on accessing unauthorized sites. Brazil has its own rules for authorization and advertising - a foreign license does not replace a local permit.

1) What is it all about

In the global online entertainment market, there are often two "points of attraction" for operators:

Curacao is traditionally a more affordable registration for online games, historically with a simplified login model and international orientation.
Malta (MGA) is a mature European jurisdiction with detailed requirements for capital, risk management, technical audit and player protection.

Both jurisdictions issue permits operating under their own right and conditions of "export" activity. But the right to serve Brazilian users is formed by Brazilian law: local authorization, compliance with the advertising code, Responsible Gaming, KYC/AML and taxes are needed.

2) What foreign licenses usually "carry" - and where are the limits

What they give:

formal legal capacity of the operator in the country of registration;
access to international PSPs/banks, content providers and test labs;
basic standards of internal policies (risk management, information security, reporting).

What they don't give in Brazil:

rights to work with Brazilian consumers without local authorization;
immunity from Brazilian advertising, taxation, RG and KYC/AML regulations;
"safe for Brazilian player" status by default (ADR/Ombudsman outside the country may not be applicable).

3) What are the differences in approaches (very short and without "legal lectures")

Malta (MGA) - a guideline for strict compliance: beneficiaries and fit-and-prop, financial stability, segment types of licenses, mandatory RG procedures, RNG and live studio tests, reporting and audit.

Curacao is historically more flexible registration for international operators (in recent years, requirements have been tightened: more transparency of beneficiaries, technical control, AML). For business, this meant a quick start, but also a greater spread in the quality of practices among different companies.

💡 Conclusion: registration jurisdiction ≠ quality of service. For the Brazilian player, the key question is whether the site has local authorization and whether Brazilian protection mechanisms (RG, ADR, advertising, payments) work.

4) Brazil: How a foreign licence relates to a local box

To legally work with consumers in Brazil, the operator needs Brazilian authorization (not just Curacao/Malta).

Advertising, sponsorship, club/league collaborations, use of influencers - fall under Brazilian advertising norms and responsibility for targeting vulnerable groups.

Payments must go through authorized providers with KYC/AML, transparent returns, payment SLAs and understandable fees.

Responsible Gaming: default limits, "time out," self-exclusion, age verification, visible links to help - not "desirable," but the expected standard.

5) For whom and when foreign registration is appropriate

For B2B and export of services (hosting, studios, content providers, data integration, anti-fraud) - as part of the international structure of the group.

For multi-jurisdictional B2C groups that obtain local permits in countries of presence and use Curacao/Malta as a "domicile "/holding/part of the compliance landscape.

It is inappropriate to consider a foreign license as a "pocket pass" to a Brazilian audience without local authorization: this is fraught with blocking, fines and reputational risks.

6) Risks for Brazilian player when betting on "Curacao/Malta only"

Dispute jurisdiction: Another country's ombudsman/ADR won't always help the Brazilian consumer.

Payments and returns: complex cross-borders, weak applicability of terms/sanctions.

Advertising and responsibility: aggressive offers/bonuses, lack of local RG tools by default.

Data and payments: if PSPs are "gray," the risk of leaks, chargeback traps and locks is higher.

7) Check list of legality check (for users and clubs)

1. Is there a Brazilian authorization? Public register/official announcements whether the operator's "passport" is noticeable.

2. RG tools by default: deposit/time limits, 1-click self-exclusion, age control - before marketing and bonuses.

3. Payment hygiene: only official PSPs, PIX/cards/e-wallets with transparent SLAs and return policies.

4. ADR/Ombudsman: is there an understandable dispute procedure in Brazil and the timing of the response.

5. Advertising: 18 +, warnings, no targeting of the vulnerable, prohibition of "guaranteed winnings."

8) For operators and brands (high-level requirements)

Ownership structure and fit-and-prop: disclosed beneficiaries, "clean" history, control of conflicts of interest.

KYC/AML/SoF: risk scoring, logs, reports, personnel training.

Technologies and information security: RNG/live certification, ISO approach, 2FA, event log storage.

Responsible play: default limits, timeout, self-exclusion, behavior monitoring.

Advertising and partnerships: code for influencers/clubs, ban on insider betting, integration protocols.

9) Frequent questions (short)

Does a foreign license automatically make the site legal in Brazil? No, it isn't. We need local authorization and compliance with Brazilian standards.

Which jurisdiction is "better" - Curaçao or Malta? These are different models. But for the Brazilian user, the key is the status in Brazil, and not the "passport" abroad.

If the operator has both Curacao/Malta and Brazilian authorization? Then foreign registration is part of the global structure, and the rules for working with the Brazilian consumer determine the Brazilian norms.

10) Frame 2030: Common sense compromise

Encourage the "white" market: understandable authorization procedures, compatibility with best international practices (content audit, ADR, RG, AML).

It is tough to separate "foreign domicile" from access to local users: without Brazilian authorization - no advertising, no sponsorships, no payment integrations.

Focus on the consumer: a single RG showcase (QR self-exclusion/assistance), public reports on complaints and payment terms, transparent return rules.

Sports and integrity: banning insider betting, manipulation monitoring systems, educational modules for clubs and referees.

11) Memo to player (legitimate steps)

Use only sites with Brazilian authorization.

Include limits and 2FA; Save checks/statements.

Avoid transfers to personal accounts and "agents" in instant messengers.

In case of a dispute, follow the official ADR procedure; with signs of a problem game - self-exclusion and seeking help.

Foreign registration (Curaçao, Malta) is just a fragment of the global legal picture. For Brazil, it does not replace local authorization, advertising rules, RG and KYC/AML. A sustainable market is built where the operator is transparent to the regulator and the consumer, payments are clean and predictable, and Responsible Gaming tools work by default. This approach protects the player, gives the business an understandable framework and reduces the space for the "gray" zone.