BRAZIL Trends and Developments Contributed by: Flávia Leardini, Paula Moreira Indalecio, Rogério Taffarello and Philippe Alves do Nascimento, Mattos Filho
been a major point of criticism directed at the superior courts in Brazil. In recent years, multi-agency co-operation has become the norm, with the Federal Police ( Polícia Federal ), Public Prosecutor’s Office ( Ministério Públi- co Federal ), tax authorities ( Receita Federal ), and the CGU working together to detect and investigate com - plex schemes. The use of data analytics and cross- referencing of public and private databases has ena - bled the authorities to identify patterns of illicit activity more efficiently, as seen in recent operations targeting tax evasion, money laundering, and fraud in public procurement. Notably, the integration of digital tools has facilitated real-time monitoring of financial flows, the mapping of beneficial ownership structures, and the detection of unusual transaction patterns across multiple sectors. Organised Crime’s Infiltration into the Financial System One of the most significant developments in 2025 was the exposure of organised crime’s deep infiltra - tion into Brazil’s financial system. In a series of high- profile investigations, the authorities uncovered that the Primeiro Comando da Capital , one of Brazil’s larg - est criminal organisations, had gained control over at least 40 investment funds with assets exceeding BRL30 billion (approximately USD5.5 billion), as well as logistics assets, fuel retail networks, and even port terminals. The group used these structures to launder money and integrate illicit proceeds into the formal economy, with total movement exceeding BRL52 bil - lion (approximately USD9.5 billion). These revelations highlighted vulnerabilities in compliance and due dili - gence processes within the financial sector, particu - larly in the onboarding of clients, beneficial ownership verification, and the monitoring of complex investment vehicles. Such investigations have prompted a wave of regula - tory and legislative responses. The securities regulator (CVM), the Receita Federal and the Brazilian Central Bank have intensified supervision, requiring enhanced due diligence, stricter onboarding procedures, and greater personal accountability for senior managers and gatekeepers.
Financial institutions are now expected to implement more robust AML controls, including real-time trans - action monitoring, beneficial ownership verification, and regular staff training. The Faria Lima financial dis - trict, previously seen as a symbol of market sophisti - cation, has become a focal point for regulatory scru - tiny, with several high-profile asset management firms and fintechs subject to ongoing investigations. The episode has also sparked debate about the adequacy of Brazil’s beneficial ownership registry and the need for greater transparency in fund structures, with the CVM and Receita Federal launching joint initiatives to improve data sharing and oversight. Regulatory Maturation in Sports Betting The sports betting sector has transitioned from a peri - od of regulatory uncertainty to a fully regulated envi - ronment. The Ministry of Finance’s Prizes and Betting Secretariat ( Secretaria de Prêmios e Apostas , SPA) became operational in 2024, and as of 2025, 66 com - panies have been authorised to operate under the. bet.br domain. Monthly transaction volumes via PIX, Brazil’s instant payment system, have reached up to BRL30 billion, raising concerns about potential mon - ey laundering, match-fixing, and the need for robust consumer protection. The Senate has approved new restrictions on advertising, and a Parliamentary Inquiry Commission ( CPI das Bets ) has targeted the sector’s links to organised crime and financial fraud, with sev - eral operators and payment processors called to tes - tify. Compliance requirements for operators have become more stringent, with a focus on rigorous customer onboarding (including enhanced KYC policies), trans - action monitoring, safer gambling controls, and trans - parent incident reporting. The Central Bank and CVM have issued joint guidelines on AML/CTF for betting operators, and the Receita Federal has begun auditing the tax compliance of major platforms. The sector’s rapid growth has also attracted increased scrutiny from enforcement agencies, making robust compli - ance frameworks, whistle-blower channels, and regu - lar audits essential for market participants. In addition, the SPA has introduced a centralised monitoring sys - tem for suspicious betting patterns, and the Ministry of Justice has launched public awareness campaigns on responsible gambling.
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