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Compliance used to be the last box checked before a product went live. In Brazil’s betting market, that order has flipped, as regulation now shapes decisions from day one.
Build the product, define the commercial strategy, and ask legal later. For companies entering Brazil’s betting market, that order of priorities is becoming increasingly difficult to sustain. As the regulatory framework grows more complex and new ordinances continue to shape the sector, compliance is moving closer to the starting point of business decisions - rather than remaining the final check before they go to market.
That shift raises a question that sits at the heart of our conversation with Bárbara Teles, a lawyer specializing in regulation, compliance, and institutional relations in the gaming and betting sector: what does it really mean to be compliant in a market where the rules themselves continue to evolve?
From interpreting ordinances beyond their literal wording to preparing for requirements that may emerge in the years ahead, Teles argues that compliance is becoming less about meeting individual obligations and more about building a business capable of adapting to regulation.
A: The biggest shift was realizing that compliance stopped being a final validation step and became part of the business strategy itself.
In an unregulated market, or one still in the process of being regulated, many companies were used to developing the product, the commercial strategy, or the marketing campaign first, and only then asking legal whether it could be done. In a regulated environment, that logic has to be reversed.
Today, decisions about product, technology, payment methods, advertising, the relationship with the bettor, responsible gambling, and even user experience need to take regulation into account from the very conception. This is a highly regulated sector, with robust legislation and dozens of ordinances.
That also requires another important shift: understanding that getting a license doesn't mean the regulatory process is over. In fact, that's when it starts. The operator now lives with permanent oversight, constantly updated rules, reporting obligations, certifications, internal controls, and shifting interpretations from the regulator.
That's why regulatory planning needs to be continuous.
Regulation came to strengthen a market that already existed and was continuously developing toward genuine maturity.
A: One of the most recurring mistakes is treating regulation in an overly literal and isolated way.
A company reads a given article, sees there's no explicit prohibition, and concludes that a particular product, feature, or practice is automatically allowed. But highly regulated markets, like fixed-odds betting in Brazil, don't work that way.
You need to analyze the regulatory framework as a whole - the purpose of the rule, consumer protection and responsible gambling principles, the regulator's positions (numerous FAQs and Technical Notes), and, increasingly, the interaction between different authorities.
In the Brazilian betting sector, for example, a single decision may involve not just the Secretariat of Prizes and Betting, but also data protection, consumer defense, advertising, anti-money laundering, and the protection of children and adolescents.
Another frequent mistake is thinking: we've always done it this way and never had a problem. In a recently regulated market, a lack of enforcement in the past doesn't mean compliance.
The right question isn't just "is this prohibited?" but also "could I technically justify this decision to the regulator if questioned tomorrow?" - always assuming the action was taken in good faith.
A: Without a doubt. The main one is building compliance as something integrated into the business, not as an area whose function is simply to say "no." Compliance needs to be a partner to the business.
When legal, compliance, product, marketing, technology, and operations work together from the start, the company can anticipate risks and find regulatorily sustainable solutions without necessarily compromising user experience or commercial results. That generates an enormous advantage.
Companies that understand regulation deeply can develop products faster, adapt before their competitors, and make decisions with greater confidence.
Beyond that, in regulated markets, reputation is also a competitive asset. A consistent track record of compliance improves relationships with regulators, business partners, financial institutions, suppliers, and investors.
That's why I like to say that good compliance doesn't block innovation - it's what makes innovation sustainable.
A: The very construction of Brazil's regulated betting market significantly changed my view. From the legislative process in 2018, then 2021, and finally Bill 3626/2023, which resulted in Law 14,790/2023, through to the thematic ordinances that came out in 2024 - and continue to be published.
Watching a sector move, in just a few years, from an environment with few specific rules to one of the most regulated markets in the country showed, in practice, how business decisions made today can produce regulatory consequences years later.
It also became very clear to me that it's not enough to simply follow published rules. Often, by the time an ordinance is published, a company should already have been preparing for months.
You need to track public consultations, institutional debates, international developments, statements from public bodies, and the evolution of society's own concerns - which are reflected in parliamentary discourse.
That changed how I see regulatory planning: the best regulatory work isn't just reacting to the rule; it's being able to anticipate the direction regulation is heading.
The earlier a company recognizes that direction, the lower the cost of adapting tends to be - financially, operationally, and reputationally.
Q: What do you believe companies should start doing today with the market of the next few years in mind?
A: First, stop seeing every new regulatory obligation as an isolated project.
Companies need to build a real compliance infrastructure with governance, processes, technology, and data that can continuously absorb regulatory change.
I also believe three themes will become increasingly important: consumer protection, responsible use of data and technology, and effective responsible gambling mechanisms.
The bar will keep rising. It won't be enough to simply state that a policy or control exists. Companies will need to demonstrate, through auditable data and evidence, that these mechanisms actually work in practice.
Another essential point is investing in regulatory intelligence. Companies need to track not only what's currently in force, but what's likely to be regulated over the next two or three years. In the end, the best-prepared companies will be the ones that understand regulation isn't just an obligation to comply with. It's a strategic variable that needs to be built into business planning.
And finally, but no less importantly, companies need to understand there's a social role behind these activities. For the market to become consolidated and healthy, we need a shift in the social mindset to recognize that this sector creates jobs, income, and technology. One company's actions - positive or negative - affect everyone else, so we also need to think collectively and sustainably.
Bárbara Teles is a lawyer specializing in regulation, compliance, and institutional relations in the gaming and betting market. She is directly involved in monitoring and implementing Brazil's regulatory framework for fixed-odds betting, advising domestic and international companies on compliance, legal matters, anti-money laundering, responsible gambling, advertising, data protection, and regulatory structuring. She is Head of Compliance and Legal at Playtech Brazil, Co-founder of AMIG (the Association of Women in the Games Industry), Director of Government Relations at ABC-BET , and Vice President of the Gaming Law Commission at OAB/DF.
