The Enemy is Only One: Illegal Gambling

Interview with Amilton Noble, Hebara S/A's CEO

Brazil’s regulated betting market is no longer a “future opportunity.” It is live, rapidly maturing, and increasingly defined by enforcement and compliance. As Oddsgate has noted in its recent Brazil coverage, the direction is clear: greater centralization, higher compliance standards, and tougher action against illegal operators.

In this interview, Amilton Noble, CEO of Hebara S/A (30+ years in the lottery segment), explains why Brazil’s progress is real, but fragile, and why the market’s biggest threat is not competition, technology, or product innovation. In his words, the enemy is only one: illegal gambling.

Brazil’s iGaming Regulation has entered a defining phase

Noble’s assessment is direct: “has finally arrived and is here to stay.” But he argues that the market’s delayed structuring created distortions, because betting was legalized in 2018, yet regulation took years to fully take shape.

Oddsgate’s own regulatory reporting aligns with this “acceleration” narrative: the pace is intense, but the trajectory is becoming more centralized and more demanding for operators and suppliers.

What this means in practice: the conversation is shifting from whether Brazil will regulate, to how consistently the rules will be enforced and how stable the framework will remain.

The biggest challenge isn’t Competition, it’s Illegal Gambling

When asked about today’s biggest challenges, Noble points to one dominant risk: illegal operations.

He explains that illegal operators:

• Undermine the State;

• Damage licensed operators;

• and expose players to risk because consumers lack legal protection in disputes.

This is precisely where regulated markets either succeed or fail: consumer trust depends on enforceable standards. Oddsgate has repeatedly highlighted that tackling unlicensed operators is one of the most complex ongoing challenges in Brazil’s framework.

Noble’s central message: if enforcement doesn’t scale, illegal operators remain the “path of least resistance” for players – no matter how strong the rules look on paper.

Early Results are Strong, but Legal Certainty still matters most

Noble describes the first months as proof of the market's potential, highlighting tax collection and job creation. But he also flags what he sees as a weak point: legal certainty.

This closely aligns with a critical theme in Oddsgate’s Brazil commentary: stable regulation and the predictable application of rules are essential for operators, suppliers, and investors who need to build long-term plans.

In other words, Brazil’s opportunity is massive—but market confidence is fragile when policy signals shift abruptly.

Compliance is strict by Design and that can be a Competitive Advantage

Noble calls Brazilian legislation strict and carefully designed, opening the door for companies committed to operating inside a regulated environment.

Oddsgate has also emphasized that Brazil is “strict by design” in compliance – particularly in areas such as AML/KYC obligations and permitted payment methods in the licensed market.

For serious operators and suppliers, strict requirements can become an advantage:

• Clearer market standards;

• Stronger player trust;

• Fewer “grey-market shortcuts” among licensed peers.

But again, this only works if illegal operators face meaningful disruption. Otherwise, regulated businesses carry heavy compliance costs while unlicensed competitors avoid them.

Player Protection measures must apply to everyone – not just the Licensed Market

Noble points to Law 14.790/23 and the ordinances that followed as the basis for strong consumer safeguards. He highlights:

• Facial recognition;

• KYC;

• Responsible gaming policies.

Oddsgate’s coverage of Brazil’s regulatory updates similarly focuses on the operational impact of these measures and the government’s stance that unlicensed operators should be treated as illegal under the updated framework.

The risk Noble keeps returning to: if these protections only bind licensed operators, the market becomes structurally unfair – and players remain exposed on illegal platforms.

Tax Pressure Can Backfire by Strengthening the Illegal Market

Noble warns that treating iGaming mainly as a revenue source can be dangerous, especially when illegal gambling is still widespread. He points to proposals for sharp tax increases as a mistake, because overburdening licensed companies can push the market in the wrong direction.

This is consistent with concerns raised in industry discussions Oddsgate has covered: over-restriction and heavy burdens can unintentionally push players toward illegal operators, weakening the regulated ecosystem.

The balanced approach is straightforward:

• Taxes that sustain oversight and public goals;

• Without suffocating legal operators who already compete with illegal platforms.

Enforcement is a Scale Problem and it requires Coordination

Noble highlights enforcement actions and the vast gap between illegal and legal market presence. He concludes that the only way to win is with intelligence, integration, and consistent enforcement.

Oddsgate has similarly underscored that regulation is evolving, with implications for player protection and market fairness – and that enforcement against illegal operators remains a core challenge.

This is where policy becomes practical:

• Blocking and disruption;

• Payment rail controls;

• Platform compliance verification;

• and cross-agency coordination.

Adaptability: eSports and New Formats must evolve without shocking the Market

Noble believes regulation should adapt to new formats (like eSports), but stresses that changes must be gradual. Businesses planned around the licensing model need stability.

Oddsgate’s “sports betting law updates” timeline supports this view of regulation as a sequence of milestones – moving from the legal framework into operational detail and ongoing refinement.

A modern framework must be alive – yet predictable.

What foreign Investors look for: Stability + Real Anti-Illegal Action

Noble sees Brazil as one of the world’s most significant opportunities, but he warns that uncertainty drives investment away. The signals investors want are straightforward:

• Stable rules and institutional consistency;

• Balanced taxation;

• and credible enforcement that make illegal operations harder to access than legal ones.

Oddsgate’s own positioning on Brazil’s current phase reinforces that the market is moving toward stronger compliance and anti-illegal action—but the outcomes will depend on execution, not intent.

Conclusion: a Regulated Future depends on defeating the Only Enemy

Brazil’s regulated market can become one of the largest in the world. The foundations are being built: operational rules, compliance standards, and player safeguards.

But Noble’s warning is the key takeaway: If illegal gambling remains competitive and accessible, it will undermine everything regulation is trying to achieve.

A safe market requires more than good laws – it requires consistent enforcement, stable rules, and licensed operators committed to protecting players and building long-term trust.