One of the fundamental aspects of the regulated betting market in Brazil is the protection of bettors. Many companies operating in this sector are foreign, which can make users wary of potential risks, such as encountering problems and not being able to hold an operator accountable from thousands of kilometers away. Fortunately, the regulatory framework established by the Secretariat of Prizes and Betting of the Ministry of Finance (SPA/MF) addresses several issues that enhance consumer security.
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Among these is the separation of operators’ accounts, a topic outlined in Normative Ordinance No. 615 of the SPA/MF. Betting platforms must maintain two separate accounts: a transactional account and an operational (proprietary) account. The transactional account holds the funds deposited by users, and it is from this account that bettors’ withdrawals are made. The operational account should only be used for operational expenses and liquidity management. A key point is that both accounts must be held at financial institutions authorized by the Central Bank of Brazil.
Why Is This Separation Important?
A crucial aspect of any betting company is its liquidity. When offering betting options, an operator may go through loss-making periods if bettors achieve favorable sports outcomes. Liquidity management, which has an entire chapter dedicated to it in the ordinance, ensures that the company always has sufficient funds available to pay users—even in a hypothetical scenario where every user decides to withdraw their winnings simultaneously.
This is why the separation between transactional and operational accounts is essential. Consumer deposits cannot be mixed with funds used for business expenses, such as payroll, ensuring that user funds are always available for withdrawal. Additionally, the ordinance explicitly states that operators must implement measures to “manage their exposure to liquidity risk.” Article 8 outlines these policies:
I – Establish objective methodologies for calculating exposure limits;
II – Implement processes to measure, monitor, and mitigate liquidity risk over different time horizons, including intraday;
III – Maintain a contingency plan detailing additional funding sources, responsibilities, and procedures for handling liquidity stress situations.
One of these additional funding sources may be the company’s operational account. In a “liquidity stress” situation, as defined by law, this account may be used to pay users. However, the reverse movement—transferring money from the transactional account to the operational account—is strictly prohibited.
Furthermore, each betting platform must maintain a financial reserve of R$ 5 million as a last resort to ensure user payouts. Since all accounts must be held at institutions authorized by the Central Bank of Brazil, the government can take action against these funds if the regulations are violated—something much more challenging if the accounts were held abroad.
How Does This Affect You?
The regulated sports betting market in Brazil officially took effect on January 1, 2025. This means that licensed operators must comply with these account separation rules, keeping customer funds separate and ensuring greater security for users.
For those looking to participate in online betting, the key takeaway is to choose only platforms licensed by the Ministry of Finance, ensuring that their funds are properly protected.
