Fixed Odds Betting Compliance: Regulatory Challenges and Best Practices in the Igaming Market

Fabíola Martin; Eliza Remédio Alecrim

DOI: 10.22167/2675-6528-202602885

Article derived from a Final Course Work (TCC), with content based on the student’s original work and adapted to the editorial format of the E&S Magazine with the support of the ResumeAI tool, an artificial intelligence solution developed by the Pecege Institute for textual synthesis and organization.

Abstract

The recent growth of the fixed-odds betting market in Brazil has highlighted the need for regulatory structures and control mechanisms capable of mitigating the financial and social risks associated with the activity. The objective was to analyze the implementation of compliance and corporate governance mechanisms in a company operating in the sector. A qualitative and applied approach was adopted, based on a case study, which included documentary analysis of internal policies, review of specialized literature, semi-structured interview with an industry expert, and observation of organizational processes. The results indicated that the analyzed company demonstrated formal adherence to regulatory requirements, with the implementation of governance structures, anti-money laundering controls, and user protection mechanisms. However, it was found that such measures presented limitations in practical effectiveness, especially in identifying risky behaviors and mitigating impacts related to gambling addiction and users’ financial vulnerability. The analysis revealed a gap between formal compliance with regulatory obligations and the effective management of risks inherent to the activity in a regulatory context still under consolidation. It was concluded that the improvement of compliance programs in the sector depends on the adoption of more proactive, integrated, and data-driven approaches, aiming to strengthen governance and enhance user protection.

Keywords: Risk management; Corporate governance; Responsible gaming; Money laundering; User protection.

1. Introduction

The fixed-odds betting market in Brazil has undergone a recent regulatory transformation, although the exploration of games and betting in the country has a significantly older historical trajectory. Marked by cycles of permission and prohibition, the activity has been profoundly altered in recent decades by the expansion of digital platforms and the emergence of new forms of online betting.

This regulatory consolidation occurred in parallel with an expressive expansion of activity, moving billions of reais and involving millions of users (BANCO CENTRAL DO BRASIL, 2024). Such growth highlights not only the economic relevance of the sector but also the dimension of regulatory challenges. Historically, the exploration of games and betting has been associated with social risks and negative externalities, such as money laundering and socioeconomic impacts related to indebtedness and gambling addiction (GOUVÊA; SOARES, 2025).

Fixed-odds betting is legally defined as the lottery modality in which the bettor acquires the right to a prize calculated by a multiplication factor (odds) previously fixed on the amount bet, incident on the result of a future and uncertain event, of a sporting or online game nature (Brazil, 2023). This modality is part of the broader iGaming genre, which comprises the set of games and bets exploited in a digital environment.

The enactment of Law No. 13.756/2018 and its regulation by Law No. 14.790/2023, along with the creation of the Secretariat of Prizes and Betting of the Ministry of Finance (SPA/MF) and the issuance of specific ordinances, established a regulatory framework for the sector. These norms aim at consumer protection, money laundering prevention, and the promotion of responsible gaming. However, despite the advances, a gap persists in defining mechanisms for monitoring and mitigating negative externalities, requiring companies themselves to fill this regulatory gap (GOUVÊA; SOARES, 2025).

In this scenario, corporate governance assumes special relevance, as state obligations must be accompanied by internal structures capable of managing risks not fully foreseen by legislation. Compliance, in turn, transcends mere formal adherence to norms, adopting a strategic and proactive character. It aligns with the principles of Environmental, Social and Governance (ESG), especially in the social pillar, by incorporating user protection and damage prevention as central elements.

Within the scope of responsible gaming, the effectiveness of measures adopted by operators is crucial. Contemporary compliance demands the construction of a decision architecture that influences user behavior, reducing compulsive practices. Data-driven technologies, such as behavioral pattern detection algorithms, emerge as potential tools for preventive action, allowing interventions before the explicit manifestation of risky behaviors. The practical and effective implementation of these mechanisms is fundamental for the sustainability and integrity of the sector.

Given the regulatory complexity and practical challenges in implementing effective controls, the need to investigate how companies in the sector are adapting their internal structures is justified. Therefore, the present work aims to analyze the implementation of compliance and corporate governance mechanisms in a company operating in the Brazilian fixed-odds betting sector, based on a case study. It seeks to examine, in practice, how regulatory requirements have been internalized in the organizational process of the aforementioned company, as well as to identify the main challenges faced in its operationalization, especially in relation to risk management, money laundering prevention, and user protection. It also intends to evaluate the limitations of the adopted structures, based on documentary analysis and the perception of interviewed industry experts, contributing to an understanding of compliance and governance practices in the fixed-odds betting sector.

2. Material and Methods

This research was characterized as a case study of an applied nature and qualitative approach, developed between October 2025 and March 2026. The objective was to deepen the understanding of the practical application of compliance and corporate governance mechanisms in a private company in the fixed-odds betting sector, located in the State of São Paulo and selected for its performance in the regulated Brazilian market.

The company’s institutional participation was formalized through a term of authorization and commitment, signed between the organization and the researcher. This term ensured the use of data exclusively for academic purposes and guaranteed the confidentiality of the company’s identity, as well as information that could enable its direct identification.

Data collection employed a combined methodology, which included bibliographic and normative review, documentary research, semi-structured interview, and observation of organizational processes. This approach allowed for an integrated analysis of legislation, institutional documents, and the practical perception of the sector’s challenges.

The bibliographic and normative review was carried out by analyzing the legislation applicable to fixed-odds betting, covering federal laws and ordinances issued by the Secretariat of Prizes and Betting of the Ministry of Finance. Additionally, specialized doctrinal works on regulation, corporate governance, and compliance were consulted.

The documentary research consisted of the analysis of the company’s internal institutional documents, systematized according to their purpose and compliance or governance pillar. Compliance policies and manuals were examined, including the risk management manual, the internal risk assessment (AIR), the anti-money laundering and terrorist financing (AML/CFT) policy, and internal procedures and controls.

Procedures for monitoring, reporting of atypical situations, and responsible gaming and privacy policies were also analyzed. User risk management manuals and due diligence for employees (KYE), partners (KYP), and suppliers (KYS) were also considered, aiming for a structured understanding of internal practices.

The semi-structured interview was conducted with a professional working in the regulatory sector of betting, who participated in relevant stages of the development and implementation of the Brazilian regulatory framework. The interview instrument consisted of a script of open-ended questions, developed based on the specific research objectives.

The observation of the company’s organizational processes and operational flows was carried out through a combined qualitative approach. Institutional documents were interpreted and the practices adopted by the company were directly observed, with access to internal systems and money laundering prevention monitoring tools.

Additionally, internal meetings of the compliance area were attended, which allowed for an understanding of the decision-making dynamics and the interaction between the involved areas. This approach made it possible to distinguish formally documented compliance from its effective application in the operational environment.

For the treatment of the collected data, a structured procedure of qualitative content analysis was employed, divided into three stages. Firstly, the institutional documents and the interview transcription were read and coded, based on thematic categories aligned with the specific research objectives.

Thematic categories included governance and risk management, anti-money laundering, user protection, and responsible gaming. Subsequently, the evidence obtained from documentary research, semi-structured interviews, and direct observation of internal processes was triangulated.

The triangulation aimed to identify convergences and divergences between formally documented compliance and its practical implementation. Finally, the triangulated evidence was confronted with the revised theoretical and normative framework, grounding the study’s conclusions.

3. Results and Discussion

The analysis of the implementation of compliance mechanisms and corporate governance in the studied company revealed a formal adherence to the regulatory requirements of the fixed-odds betting sector in Brazil, which is in a consolidation phase. The existence of governance structures, anti-money laundering controls, and user protection mechanisms was verified, as documented in internal policies and manuals. However, the research showed that the practical effectiveness of these measures presents significant limitations, especially in the proactive identification of risky behaviors and in mitigating social impacts, such as gambling addiction and user financial vulnerability. This gap between regulatory compliance and effective management of the risks inherent in the activity constitutes a central challenge for the sector.

The Brazilian regulatory landscape for fixed-odds betting, although historically marked by cycles of permissiveness and prohibition, has undergone a significant transformation with the enactment of Law No. 13.756/2018 and its regulation by Law No. 14.790/2023. These laws, along with the creation of the Secretariat of Prizes and Betting (SPA/MF) and the issuance of specific ordinances, have established a milestone for the sector. This evolution represents a shift from a prohibitive model to a regulatory approach based on control and supervision, seeking to protect consumers, prevent money laundering, and promote responsible gambling (GOUVÊA; SOARES, 2025). However, the literature indicates that there is still a gap in defining mechanisms for monitoring and mitigating negative externalities, transferring to companies the responsibility of filling this gap.

Governance structure and risk management

The company’s documentary analysis revealed the existence of a formal set of corporate governance and risk management policies and procedures, including a risk management manual, an internal risk assessment (AIR), and compliance policies. These instruments demonstrate a systematized approach to the identification, classification, and mitigation of regulatory, operational, and reputational risks, aligned with industry requirements. The AIR, in particular, associates risk classification with control and monitoring measures, indicating the formalization of follow-up procedures. This formal structure is an important advancement in the Brazilian regulatory context.

Despite the formalization, the effectiveness of these mechanisms depends on their practical application in daily operations, which proved to be a challenge. The interview with a regulatory sector specialist corroborated this perception, highlighting difficulties related to technological implementation, the maturity of internal processes, and the organizational culture of companies in adapting to the new environment. In a scenario where regulations establish general guidelines but do not exhaustively detail the means of implementation, operators have room to define their own risk management and control mechanisms, which gives corporate governance a crucial role in translating regulatory requirements into internal processes.

Governance takes on a particularly relevant role when the risks of business activity transcend the immediate economic interests of the organization. In the betting sector, an effective governance structure must ensure that decision-making considers the regulatory and social impacts of the operation, bringing internal control mechanisms closer to the risks concretely produced by the activity (GOUVÊA; SOARES, 2025). It was observed, however, that some activities subject to regulatory requirements, especially in the areas of marketing, product, and technology, were implemented without prior validation from the compliance area, as indicated by institutional records of regulatory occurrences.

This finding suggests that the mere existence of formal compliance policies and structures does not guarantee their full incorporation into the organization’s decision-making processes. The main limitation identified does not lie in the absence of formal governance instruments, but in the need to broaden their preventive integration into operational areas whose decisions can generate regulatory repercussions. Compliance, therefore, is not restricted to the elaboration of documents or the formal fulfillment of obligations, but requires active participation in internal decision-making processes, prevention, and control of risks associated with operations, which is fundamental for the sustainability and integrity of the sector.

Money laundering prevention and internal controls

Anti-money laundering (AML) and counter-terrorist financing (CTF) prevention constitutes one of the most sensitive pillars of compliance in the betting sector, especially after events such as Operation Integration and the installation of the CPIBETS, which investigated possible links between the sector and criminal organizations (AMARAL; COSTA, 2025). The analysis of the company’s AML/CTF policy and internal transactional monitoring procedures demonstrated that the formalization of controls is more consolidated than some aspects of their operationalization, a finding that aligns with the interviewed expert’s perception of the practical challenges faced by operators.

The studied company structured specific mechanisms for PLD/FT, including formal policies, operation monitoring procedures, user identification, and reporting of atypical situations. These instruments reflect the concern to meet regulatory requirements, especially in the identification, analysis, and communication of suspicious operations. The adoption of continuous transaction monitoring procedures, through an automated platform and previously defined risk criteria, indicates the incorporation of a risk-based approach, aiming for greater efficiency in detecting irregularities and prioritizing control efforts on more sensitive operations.

The betting sector is particularly vulnerable to money laundering due to the high volume and speed of transactions, as well as the possibility of using platforms to conceal and integrate illicit funds (FERNANDES; NOJIRI, 2025). In this context, robust internal controls and continuous monitoring mechanisms are essential. Law No. 14.790/2023 and Ordinance SPA/MF No. 1,143/2024 impose detailed obligations, such as AML/CFT policies, definition of roles and responsibilities, risk identification and assessment, documented risk matrix, periodic training, and communication of suspicious operations to Coaf.

The company’s documentary controls, in theory, encompass the main warning signs to be monitored, such as financial movements incompatible with the bettor’s economic capacity, sudden changes in movement patterns, and operations involving high or fractional amounts. However, the effectiveness of these mechanisms faces practical limitations due to the sector’s operational complexity, the high volume of daily transactions, and the constant evolution of strategies for concealing illicit funds. The main challenge, according to the specialist, is not the existence of formal policies, but the ability to operationalize these controls efficiently and adaptably to the sector’s dynamics.

Responsible gaming and vulnerability

The company’s compliance structure also incorporates user protection mechanisms, with responsible gaming policies and self-exclusion or operational limits tools. These instruments aim to mitigate risks associated with compulsive behavior. However, assessing their effectiveness requires understanding the profile and motivations of users. Recent studies indicate that younger individuals, with lower income and under financial stress, are more prone to gambling (ABREU; BRESSAN, 2025). The perception of betting as a form of income supplementation, a distortion in risk assessment, is recurrent.

ANBIMA (2024; 2025) data reinforces this scenario, indicating high adherence of the Brazilian population to betting, with approximately 15% of the population over sixteen years of age engaged in the activity. Among bettors, 10.81 million, representing 47% of the total, are in debt, evidencing a strong association with financial vulnerability. Additionally, 4 million bettors consider betting an investment, revealing a distortion in risk perception, and 3 million show a tendency towards compulsive behavior, indicating a relevant risk of gambling addiction. These data underscore the need for special attention to protection mechanisms and responsible gambling, especially in contexts of economic vulnerability.

The economic dimension, however, is not the sole motivation for participating in betting. The activity can also be linked to the pursuit of entertainment experiences and emotional involvement with sports events, adding a component of anticipation and excitement (CAVALCANTE, 2024). The interview with the industry expert corroborates this analysis, highlighting that failures in player protection are among the main regulatory infractions. Although the company implements the minimum required mechanisms, such as age verification and self-exclusion, these measures are predominantly reactive, depending on user initiative or objective criteria that do not always capture complex risk patterns.

The use of technologies based on data analysis, artificial intelligence, and machine learning is explored as support in identifying risk behaviors, processing information such as betting frequency, amounts wagered, and session duration. However, the study demonstrates that these solutions are still more oriented towards identifying already manifested harms than towards early prediction, evidencing room for the evolution of preventive responsible gaming mechanisms. In the analyzed case, greater development of these tools was observed for transactional monitoring and fraud and AML/CFT prevention, but their integration into responsible gaming mechanisms for preventive action is still incipient.

This characteristic reveals a structural limitation in the analyzed compliance programs, which, despite being formally compliant, do not yet consistently incorporate a proactive approach based on the user’s decision architecture. Measures remain centered on responses to consummated events, such as self-exclusion requests, indicating a departure from more advanced responsible gaming practices that presuppose anticipated, data-driven interventions. This limitation is even more relevant given the increase in social problems associated with the activity, such as compulsive gambling and indebtedness (ESTEVANATTO; MENDES, 2025).

A sensitive point observed is the dilemma between user protection and the economic interests of the operation, especially in relation to high-value bettors, or *high rollers*. Users with a high betting volume can represent a significant portion of the company’s revenue, but they can also show signs of compulsive behavior. Restrictive measures, such as betting limits or account blocking, can directly impact revenue, highlighting a structural conflict between commercial objectives and compliance guidelines. This reinforces the importance of governance mechanisms that ensure the prevalence of user protection criteria over immediate economic interests.

In this context, it becomes crucial to evaluate whether the company’s governance structures incorporate performance indicators (KPIs) related to compliance and responsible gaming capable of influencing strategic decision-making. It is observed that, in practice, financial metrics, such as *Gross Gaming Revenue* (GGR), corresponding to the gross revenue from betting operations, tend to predominate in performance evaluation. Although no compliance indicators directly linked to variable executive remuneration have been identified, profit-sharing mechanisms are tied to the company’s profitability, reinforcing the centrality of economic indicators without necessarily incorporating, in an equivalent manner, user protection and social risk mitigation metrics.

The integrated analysis of the obtained data allowed us to identify that the Brazilian regulatory model for fixed-odds betting presents advances in the formal structuring of governance obligations, AML/CFT, and user protection. The establishment of clear regulatory requirements and oversight mechanisms indicates a significant shift in state action, prioritizing regulation and control. However, the effectiveness of this model still faces important limitations in the operationalization of regulatory guidelines by companies. The practical implementation of compliance mechanisms presents challenges related to process maturity, integration between internal areas, and the ability to adapt to the sector’s dynamics.

In the field of money laundering prevention, the company sought to structure controls compatible with regulatory requirements, including transaction monitoring and identification of atypical patterns. However, operational complexity and the high volume of transactions impose limitations on the effectiveness of these mechanisms, requiring constant technological and methodological improvement (FERNANDES; NOJIRI, 2025). Regarding user protection, the findings indicate a predominance of reactive measures, such as self-exclusion tools and operational limits, which prove insufficient to deal with the complexity of behaviors associated with gambling addiction and financial vulnerability (ANBIMA, 2024; ESTEVANATTO; MENDES, 2025).

The interview with the specialist reinforces that the challenges are not limited to the existence of norms, but to the capacity for internalizing these requirements in the organizational context, including the consolidation of an adequate governance culture. This analysis highlights a gap between the normative design and its effective practical implementation, where compliance assumes a predominantly formal function, to the detriment of a more strategic and risk management-oriented performance. This mismatch is particularly relevant in a sector with high exposure to financial, operational, and social risks, requiring that the improvement of compliance depends on the development of companies’ internal capabilities, including the use of advanced technologies and behavioral analyses in user management (RAGAZZO; RIBEIRO, 2012).

Given the identified limitations, improving the company’s compliance structure requires strengthening preventive mechanisms for monitoring gaming behavior, allowing for the early identification of relevant changes in platform usage patterns. This implies defining clear criteria to identify risky behaviors and adopting internal analysis and intervention procedures. Additionally, it is essential to expand the use of technological resources in user protection, integrating behavioral information into responsible gaming mechanisms, which can be verified by incorporating these parameters into internal monitoring procedures and by recording the measures adopted based on identified alerts.

Another crucial aspect for improvement is the need for greater integration between the indicators used to monitor commercial activity and the criteria related to the protection of users in vulnerable situations. The analysis showed that economic objectives and protection mechanisms can generate tensions, requiring the governance structure to adequately address these situations, especially when users of greater economic relevance present elements indicative of risk. It is therefore recommended that decision-making processes simultaneously consider commercial and responsible gaming criteria, ensuring that user-related risk factors are incorporated into decisions involving their maintenance, relationship, or commercial treatment.

Finally, the research identified limitations in the preventive integration of the compliance area into the decision-making processes of operational areas subject to regulatory requirements, such as marketing, product, and technology. Although the company has formal compliance policies and structures, situations were observed where activities with regulatory implications were conducted without prior validation. As an improvement measure, it is recommended to establish formal workflows that determine the hypotheses in which compliance participation should occur before the implementation of initiatives in these areas. The effectiveness of this measure can be verified by the existence of these workflows, the definition of the responsibilities involved, and the record of validations performed before the implementation of activities subject to regulatory requirements.

In summary, the results indicate that, although the analyzed company complies with the minimum regulatory requirements, the effectiveness of its compliance mechanisms still faces relevant limitations, especially in its preventive action capacity. The adopted model remains predominantly oriented towards formal adherence to regulatory requirements, with room for evolution towards a more strategic, integrated, and data-driven approach. This improvement is essential for compliance to assume an active role in mitigating social impacts associated with the activity, aligning with ESG principles, especially the social pillar, and contributing to a more sustainable and responsible operation in the fixed-odds betting sector.

4. Conclusion

The study aimed to analyze the implementation of compliance and corporate governance mechanisms in a company operating in the Brazilian fixed-odds betting sector, examining the internalization of regulatory requirements and the challenges in risk management, anti-money laundering, and user protection. It was found that the analyzed company demonstrated formal adherence to regulatory requirements, with the implementation of governance structures, anti-money laundering controls, and user protection mechanisms. However, it was observed that such measures presented significant limitations in practical effectiveness, especially in the proactive identification of risky behaviors and in mitigating impacts related to gambling addiction and user financial vulnerability. This finding highlighted a gap between formal compliance with regulatory obligations and the effective management of risks inherent to the activity in a regulatory context still under consolidation. The research contributes to a deeper understanding of compliance and governance practices in this evolving sector, emphasizing the need for more strategic and data-driven approaches.

The findings suggest that the improvement of compliance programs in the sector depends on the adoption of proactive, integrated, and data-driven strategies, aiming to strengthen governance and enhance user protection. It is recommended to strengthen preventive mechanisms for monitoring gaming behavior, expand the use of technological resources in user protection, and increase the integration between commercial indicators and protection criteria in decision-making processes. Additionally, it is essential to establish formal workflows for the prior validation of compliance in operational areas such as marketing, product, and technology. As a limitation, it should be noted that the analysis was based on a single case study, which restricts the generalization of the results. It is suggested that future research expand the scope of analysis, including multiple companies and comparative approaches, to investigate the effectiveness of compliance mechanisms in mitigating risks in the sector more comprehensively. This evolution is essential for compliance to assume an active role in mitigating social impacts, aligning with ESG principles and promoting more sustainable and responsible practices.

Bibliographic References

BANCO CENTRAL DO BRASIL (BACEN). Análise técnica sobre o mercado de apostas online no Brasil e o perfil dos apostadores. Estudo especial nº 119. Disponível em: https://www.bcb.gov.br/conteudo/relatorioinflacao/EstudosEspeciais/EE119_Analise_tecnica_sobre_o_mercado_de_apostas_online_no_Brasil_e_o_perfil_dos_apostadores.pdf. Acesso em: 23 mar. 2026.

Brasil. 2023. Lei 14.790, de 29 de dezembro de 2023. Dispõe sobre a modalidade lotérica denominada apostas de quota fixa; altera as Leis nºs 5.768, de 20 de dezembro de 1971, e 13.756, de 12 de dezembro de 2018, e a Medida Provisória nº 2.158-3

GOUVÊA, Carlos Portugal; SOARES, Pedro Henrique Figueiredo. Governança corporativa no setor de apostas de quota fixa: uma análise do cenário regulatório brasileiro. In: DIAS, Daniel; LOQUES, Luiz César Martins (coord.). Bets: a regulação do mercado de apostas. São Paulo: Thomson Reuters Brasil, 2025. p. 83–112.

Article originating from the Final Course Work of the Specialization in Compliance and ESG of the MBA USP/Esalq

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