The online betting market is experiencing an unprecedented boom in Brazil. The regulation of bets under Law No. 14,790/2023 consolidated a sector that moves billions of reais annually and has become one of the main sources of sports and digital sponsorships.
However, along with its expansion come increasing warnings: the vulnerabilities of this ecosystem to money laundering. The use of digital platforms, cross-border payments, and partnerships with influencers creates fertile ground for the concealment of illicit funds — challenging traditional investigation and compliance mechanisms.
The betting market in Brazil: between formalization and risk
The regulation of fixed-odds betting in 2023 marked a turning point. Until then, the sector operated in a gray area — with platforms based abroad but freely accessible to Brazilian users.
With the new law, the State recognized bets as a legitimate economic activity, subject to taxation and oversight by the Ministry of Finance. Yet, control weaknesses remain significant, especially regarding the tracking of the origin and destination of funds.
It is a market that moves billions annually, mostly through digital payments and e-wallets. In this decentralized, high-liquidity, and low-traceability environment, the risk of money laundering finds fertile ground.
The role of digital influencers
The online betting phenomenon is deeply tied to influence marketing. YouTubers, streamers, and former athletes are among the professionals promoting betting platforms on their networks, often through affiliate links or sign-up bonuses.
Although advertising contracts may seem simple, they can conceal criminal risk relationships. An influencer promoting an unlicensed betting site, for instance, may be liable for irregular advertising — and, in more complex scenarios, may become indirectly involved in illicit financial movements.
Performance-based remuneration (commissions on bettors’ losses) creates opaque incentives and may connect influencers to financial flows that are difficult to trace. Recent investigations by the Federal Police and COAF have pointed to the use of marketing contracts and digital rewards as tools for concealing illicit funds.
How money laundering infiltrates the betting ecosystem
The classic money laundering cycle — placement, layering, and integration — easily adapts to the online betting environment:
- Placement: illicit funds are deposited into betting accounts or intermediaries;
- Layering: simulated bets, transfers between players, and cryptocurrency payments obscure the money’s origin;
- Integration: funds reenter the financial system disguised as legitimate winnings or advertising income.
The use of shell companies, crypto assets, and proxies increases investigative complexity, especially when platforms are based in low-transparency jurisdictions.
We are facing a new typology of money laundering — digital, decentralized, and fragmented — where the line between entertainment and financial crime becomes blurred.
Yet, investigative intelligence mechanisms have evolved in parallel, resulting in several police operations that have led to the arrest of influencers and professionals in this market — such as the recent case in which the Federal Police alleged the receipt of funds from a criminal scheme.
These investigations show that companies linked to influencers can be used to conceal the origin of illicit funds, acting as intermediaries between criminal schemes and the formal market. In general, proceeds from fraud, simulated bets, or illegal operations are transferred through advertising contracts, sponsorships, or marketing payments, giving illicit money a veneer of legitimacy. The use of multiple corporate layers and hard-to-trace digital relations makes financial verification and accountability even more challenging for authorities.
The role of criminal defense and legal compliance
In this context, criminal law practice plays a vital role.
Lawyers advising betting companies, marketing agencies, or influencers must go beyond contract analysis: they need to understand the typologies of money laundering in the digital environment and adopt enhanced due diligence in every transaction.
Recommended best practices include:
- Verifying the license and legality of the platform before entering partnerships;
- Requiring identification of beneficial owners and proof of payment origins;
- Including compliance and transparency clauses in advertising contracts;
- Monitoring unusual transactions and crypto payments;
- Keeping auditable accounting and tax records.
In criminal litigation, the defense should demonstrate the absence of intent and separation between lawful activities and illicit flows.
Understanding the market logic — payment systems, affiliations, and transfers — is what distinguishes a generic defense from a strategic one.
Conclusion
The rise of online betting presents new challenges to economic criminal law.
The digitalization of gaming and the rise of influencers create legitimate business opportunities but also new avenues for the concealment of illicit capital.
It is up to the legal profession — especially criminal lawyers — to understand these dynamics, build compliance solutions, and, when necessary, provide technical and strategic defense to those acting in good faith in a still-maturing regulatory environment.
Combating money laundering in betting is not just a police issue — it is a legal and economic challenge that requires balance between business freedom, transparency, and accountability.
If your company operates in the digital, betting, or influencer market, contact Lucchesi Advocacia to learn how to implement compliance practices and mitigate criminal risks.
