TL;DR: Brazil's Provisional Measure No. 1,394, published September 25, 2026, bans fixed-odds betting and gives banks and payment institutions a statutory refund job: within seven days of receiving a CPF-keyed list from each operator, return every bettor's balance to an account the bettor holds, report unrefunded amounts to the Secretariat of Prizes and Betting, and sweep the rest to Caixa Econômica Federal. The Finance Ministry estimates R$1.7 billion sits in bettor wallets, with bank refunds due October 9 to 14. The Central Bank rulebook for blocking betting payments over Pix is still unwritten.
What Changed on September 25
Provisional Measure No. 1,394 prohibits the operation, offering, intermediation, and advertising of fixed-odds betting in Brazil, physical or virtual, including by operators abroad serving people in Brazil. Article 1 covers real sports events and virtual online gaming events, so casino-style products fall alongside sportsbooks. The Portuguese text is on Planalto and an English translation was published by iGaming Brazil the same day.
Three provisions bite immediately for anyone holding an operator's transactional account. Article 4 terminates every authorization under Law No. 14,790/2023 thirty days after publication, with no refund of the grant fee. Article 6 bars new authorizations. Article 7, paragraph 1, prohibits new deposits into operators' transactional accounts from the date of publication, with one carve-out for proceeds from redeeming financial assets in which bettor funds were already invested. Inbound credits to an operator's account after September 25 are therefore prohibited by default, and any exception must trace to a documented asset redemption.
The Calendar Between Now and October 14
The measure runs on day counts from publication: ten days for operators to disable sites (Article 7), two more to hand over refund lists (Article 8), and seven from receipt for institutions to refund (Article 9). According to O Globo's September 28 explainer, bettors can withdraw until 23:59 on October 5, sites go dark in the first minute of October 6, and banks refund automatically between October 9 and 14.
The Article 9 clock runs from receipt of each operator's list, not from a calendar date, and coverage differs on the hand-off window (O Globo says October 6 to 7, iGaming Brazil October 7 to 8), so log receipt per operator and compute the deadline from that.
What Operators Must Send Under Article 8
Article 8 defines the file banks will work from. Within two days of disabling access, each operator must ensure liquidity for full reimbursement (balances, stakes on voided bets, and prizes due), send its account-holding institutions an itemized list of bettors with CPF numbers, amounts to be refunded, and originating accounts, and send the same list to SPA with proof of funds. Paragraph 1 requires refund funds to stay segregated in the transactional accounts, with movement for any other purpose prohibited. Paragraph 2 sets a daily fine of R$200,000 for non-compliance.
For the account-holding institution, the operator's balance should be frozen for anything other than bettor refunds from the moment sites go dark, and outbound instructions that do not match the list should be held. Brazil had 188 authorized operators at the time of the ban, according to Global Gaming Insider, and the daily fine rewards sending something on time over something clean.
The Seven-Day Refund Runbook Under Article 9
Article 9 places four obligations on institutions holding operator accounts. The caput requires full restitution within seven days of receiving the Article 8 list, by transfer to an active deposit or payment account held by the bettor and identified by CPF; paragraph 1 prefers the originating account but permits another in the bettor's name. Paragraph 2 requires an itemized report to SPA covering amounts refunded and not refunded, naming account holders and the reasons preventing refund. Paragraph 3 sends unrefundable funds to a specific Caixa Econômica Federal account, under Ministry of Finance supervision, with each bettor's amount individually identified. Paragraph 4 keeps operators liable for shortfalls.
Operationally, that is a sequence:
Step 2 is where the compliance risk sits. A deposit that originated from an account not held by the bettor is the pattern a mule account investigation looks for, and the refund run will surface those cases at scale. Returning funds to a third party's account would breach Article 9 and complete a laundering loop; those lines belong in the exception report, not the payment file. Given uneven operator KYC files, institutions should expect a material exception rate and staff for it.
Obligations That Survive October 14
Termination does not wipe the slate. Article 10 keeps operators liable for the authorized period on tax and regulatory obligations; on prevention of money laundering, terrorist financing, and proliferation financing; and on keeping records intact and accessible for a minimum of five years, expressly including those on bettors, bets, financial transactions, and prize payments. Article 11 keeps terminated operators reporting through Sigap on bettors, deposits, withdrawals, transactional accounts, remaining balances, and the refund itself.
For banks and payment institutions, the operator remains a customer with live AML obligations after its site is dark, so its account should stay open until the refund, SPA report, and Caixa sweep are complete, and retention of refund files and exception classifications should match the five-year floor in Article 10. Reporting to COAF continues on the institution's own footing: an operator whose list does not reconcile with its account, or whose balance moved after September 25 for anything other than bettor payments, is a reportable pattern.
Articles 14 and 15: The Payments Block Still Being Written
Article 14 prohibits financial institutions, payment institutions, and participants in payment arrangements, including instant payment arrangements, from processing, settling, or facilitating betting-related transactions, except those needed to wind down and refund bettors. It applies "in accordance with regulations issued by the Central Bank of Brazil," and paragraph 1 obliges arrangement instituters to bind all participants, including those outside Central Bank authorization, and to exclude non-compliant ones.
Article 15 directs the Central Bank to build an electronic data-communication system so institutions can reject transactions and return funds through interbank channels where they relate to illegal betting, within real-time transfers settled on Central Bank systems: a Pix reject-and-return mechanism. Finance Minister Dario Durigan said on September 25 that the block would be built "a priori" into the payment arrangement, automatically covering any CNPJ whose purpose is online betting, over Pix and TED, according to Estadão reporting carried by InfoMoney. None of the implementing rules existed as of September 28. O Globo reported that the text sets no deadline for the Central Bank and does not specify how betting payments will be identified, and a September 26 GX Capital analysis noted that banks will need to reconcile registry data, CNAE codes, and payee information with no standard yet for mixed-activity companies.
What does exist is SPA/MF Ordinance No. 2,750/2026, published September 14, which already requires institutions to monitor illegal-betting flows, report to SPA by the next business day, and block on SPA notice. iGaming Business summarized its red flags: repeated reload-sized deposits, senders with no commercial relationship to the recipient, successive new Pix keys after blocks, new companies receiving thousands of microtransactions, and gateway intermediaries. After October 6 the authorized-operator list is empty by definition, so monitoring becomes purely about the illegal market. The sibling article on detecting illegal bets in Pix flows covers that typology, and the mechanics of behavioral transaction monitoring apply directly.
Congress, the Courts, and Planning Under Uncertainty
A provisional measure has the force of law on publication but must be approved by Congress within 120 days to remain in force, as Reuters reported on September 25; if it lapses unvoted, the prior framework is restored. Valor International reported on September 28 that industry associations are weighing a direct action of unconstitutionality before the Supreme Federal Court or a collective writ of mandamus. Neither moves the October deadlines. Institutions should build the refund run to the statutory timetable while documenting it well enough to unwind if the legal position changes.
Where AI Agents Fit
The Article 9 exercise is a reconciliation and exception-handling problem on a seven-day clock: 188 operators, R$1.7 billion, one line per CPF, and a reasoned report on every line that failed. Sphinx's AI agents log into the core banking and case management systems analysts already use, reconcile each operator's list against segregated balances, run the CPF-to-account ownership check, classify each exception with the reason SPA requires, and draft the report and Caixa sweep file with a citation for every decision. Sphinx customers have cleared six-month backlogs in days with the same approach, and every action is logged under the Interpretable Agentic Framework so an examiner can trace why each line was paid, held, or swept.
Frequently Asked Questions
When do banks have to refund Brazilian bettors under MP 1,394?
Article 9 gives financial and payment institutions seven days from receipt of the operator's Article 8 list, which operators must deliver within two days of taking sites offline on October 6. The government's calendar puts bank refunds between October 9 and 14, 2026, but each institution's deadline runs from the date it actually receives each list.
What must the refund list from a betting operator contain?
Under Article 8, item II, the operator must send an itemized list of bettors with their CPF numbers, the amounts to be refunded, and the accounts from which the funds originated. The same list goes to SPA with proof of funds, and the operator faces a R$200,000 daily fine for missing the two-day deadline.
What happens to balances a bank cannot refund?
Article 9, paragraph 3, requires funds that could not be returned to an active account held by the bettor to be transferred to a specific Caixa Econômica Federal account, with each bettor's amount individually identified, under Ministry of Finance supervision. The institution must also file an itemized report to SPA naming the account holders and the reason each refund failed.
Can a bank still process Pix payments to a betting company in Brazil?
Article 14 prohibits processing, settling, or facilitating betting-related transactions except those needed to wind down operations and refund bettors. The Central Bank has not yet published implementing regulations or the Article 15 reject-and-return system, so institutions are working from the prohibition itself plus SPA Ordinance No. 2,750/2026, which already requires monitoring and blocking of illegal-betting flows.
Is the Brazil betting ban permanent?
Not yet. A provisional measure takes effect immediately but must be approved by Congress within 120 days to remain law, and industry associations are preparing a constitutional challenge before the Supreme Federal Court. Until either intervenes, the refund, reporting, and payments prohibitions are in force on their statutory timetable.
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