Brazil's Central Bank Orders Banks to Block Betting Payments, but the Pix Return System Is Still to Come

Resolution BCB 590 puts the payments ban in Provisional Measure 1.394 into force in three articles and dates the duty from the day the measure was published. It leaves undone the one tool the measure told the Central Bank to build for Pix, the rail that carried most of Brazil's betting money.

• Brazil's Central Bank has ordered banks, payment institutions and every participant in a payment scheme to stop processing, settling or enabling fixed-odds betting transactions, in a three-article resolution adopted at an extraordinary board session on 28 September
• The duty runs from the date Provisional Measure 1.394 was published, 25 September, and the only exception is for transactions needed to wind operators down and refund bettors
• Banks must comply whether or not the payment schemes have rewritten their rulebooks, and the schemes may make those changes without the Central Bank's prior authorisation, provided they report them immediately afterwards
• The resolution contains no Pix-specific rule, no definition of a betting transaction, no list of blocked companies and no new reporting duty; the system the measure orders the Central Bank to build for rejecting and returning Pix transfers to illegal operators has not yet been issued
• It sits on top of the account-freezing regime banks already run against unlicensed operators, which the measure keeps and extends with forfeiture of frozen funds and reporting to the financial intelligence unit, COAF

The Central Bank Makes the Payments Ban Binding From 25 September

The Central Bank of Brazil (BCB) has put the payments part of the government's betting ban into force. Resolution BCB No. 590, adopted by the bank's Collegiate Board at an extraordinary session on Monday 28 September and published on the bank's website that evening, regulates Article 14 of Provisional Measure (MP) 1.394, which banned sports betting and online casino in Brazil on 25 September. It is signed by Gilneu Francisco Astolfi Vivan, the director of regulation, and took effect on publication.

The operative text is a single sentence. Under Article 1, financial institutions, payment institutions, payment-scheme owners and the other participants in payment schemes "are obliged, from the date of publication" of the measure, to prevent "the processing, settlement and enabling of transactions destined for fixed-odds betting lotteries". Transactions needed to close down operations and return money to bettors are exempt. A second paragraph says compliance does not depend on the schemes first amending their rules, which the measure separately requires them to do.

Article 2 deals with those amendments. Scheme owners may make the rule changes needed to comply "immediately" without prior authorisation from the Central Bank and without consulting or notifying participants in advance, but must tell the Central Bank and the participants as soon as the changes are made. Article 3 puts the resolution into force on publication. That is the whole of it.

The resolution implements a provision that was already broad. Article 14 of the measure bars banks, payment institutions and scheme owners and participants, "including instant payment" schemes, from handling betting transactions "in accordance with Central Bank regulation", and requires scheme owners to write rules binding every participant, including those the Central Bank does not authorise, and to exclude participants that break them. At the launch on 25 September the Ministry of Justice described the effect as blocking, a priori, any Pix or TED transfer to companies whose registered purpose is online betting, without prior investigation.

What the Resolution Does Not Do

Resolution 590 contains nothing specific to Pix, the Central Bank's own instant payment system. It does not define what makes a transaction "destined for" betting, publish a list of companies or tax numbers to block, or create any reporting duty beyond the schemes' notice of rule changes. Those gaps matter because the measure asks for more. Article 15 says the Central Bank "will establish" a system of electronic data communication to enable financial and payment institutions to reject transactions and make interbank returns of funds "related to illegal fixed-odds bets" in real-time transfers settled in a system the bank operates, which in practice means Pix. Resolution 590 does not create that system or set a date for it. Pix already has a Special Return Mechanism (MED) for fraud cases; the Central Bank has not said whether the betting system will build on it.

The reporting duties come from the measure itself. It amends Article 21-A of Law 14.790, the regime under which the Secretariat of Prizes and Betting (SPA) orders banks to freeze the accounts of unlicensed operators, to add a duty to report the operator's financial transactions, including atypical ones, to the Council for Financial Activities Control (COAF). Money in frozen accounts can now be declared forfeit to the Union in an administrative process without a prior court case and sent to the National Public Security Fund. Article 14 states that the new payment ban does not displace that regime.

The scale of what the Central Bank is policing is set out in its own work. A technical study it published in September 2024 estimated that betting and gambling companies received between R$18 billion and R$21 billion (approximately $3.5 billion to $4.1 billion) a month in Pix transfers during 2024, and R$20.8 billion in August 2024 alone, from about 24 million people. In April the bank also gave "games and bets" their own code, 34045, in the classification used for international payments made through eFX providers, under Resolution BCB 561.

Dating the Duty From 25 September Closes an Argument Before Anyone Makes It

The measure's phrase "in accordance with Central Bank regulation" left room to argue that the payments ban was not binding until the Central Bank had written its rules, which took three days. Article 1 removes that room by stating the obligation existed from the day of publication. The practical effect is modest, because the measure had already stopped new deposits into betting accounts on 25 September and licensed operators have been winding down since, but it matters for liability. A bank or payment institution that let a betting payment through between Friday and Monday cannot point to the absence of rules. The refund exception is equally deliberate: without it, the same banks that the measure makes responsible for returning players' balances could have been barred from moving the money.

Without a Definition, Each Bank Must Decide What a Betting Payment Is

The resolution tells banks what outcome to achieve and leaves the method to them. For the roughly 90 formerly licensed operators that is easy, because their companies and accounts are known. The hard cases are the ones the ban is really aimed at. The Central Bank's 2024 study found that the bulk of Pix flows to betting went to 56 companies registered under activity codes other than gambling, identified only by transfer patterns, and the SPA's September ordinance lists the red flags it expects banks to watch for, from transaction descriptions mentioning bets to shell companies at virtual addresses receiving fragmented transfers. Resolution 590 adds no list and no shared data, so each institution will draw its own line, and the scheme owners' rules will be the main source of consistency. The approach resembles what Brazil did with the banks earlier this month, deputising them rather than wiring the payment system to a central blocklist.

The Pix Tool Is the One That Decides Whether the Offshore Market Is Starved

The licensed operators are leaving regardless of what the Central Bank writes; they lose their licences within 30 days of the measure. The payment ban's real target is the unlicensed market, which operators' associations have warned will absorb Brazilian players. Offshore sites take Pix because Brazilian bettors use it, and a rule that obliges banks to refuse transactions they recognise does little against payments routed through intermediaries they do not. The Article 15 system, which would let institutions reject and claw back transfers tied to illegal betting in real time, is the tool designed for that problem, and it is the part still missing. Until it exists, enforcement relies on freezing accounts after the money has moved.

The Central Bank has done the simple part quickly. The measure of whether Brazil's ban holds will be how soon it delivers the harder part, and how well it works against operators that have spent years learning to look like something other than a betting site.