Double Stacks

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Application providers, digital platforms, hosting services and media intermediaries must remove irregular advertisements and campaigns after notification from the competent authority. The rapporteur’s version requires that the notification clearly and specifically identifies any content deemed irregular and ensures the right to a fair hearing and full defence. Journalistic, academic, parliamentary, artistic and opinion content are expressly protected. 

Operators and companies linked to them are also prohibited from acquiring, licensing, or exploiting rights to sporting events held in the country. In the area of ​​administrative penalties, the rapporteur’s text incorporates the new infractions into the existing sanctions system in Law 14.790 of 2023, which provides for fines of up to BRL2 billion ($392.8 million). 

One of the main changes made by Vieira is the creation of the crime of promoting unauthorised betting operators. The penalty is one to five years imprisonment. This may be increased by one-sixth to two-thirds when the promotion is done by a digital influencer, athlete, or well-known person, due to their greater ability to reach the public. 

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They recommended banning direct marketing by operators and affiliates except for essential account or safety communications.

The committee also suggested a ban on inducements (free bets, sign-up bonuses) as these promotions stimulate betting activity and recruit new or lapsed customers.

Another point of contention was content marketing and influencer promotions. The Lords committee advised treating this as advertising and, if a full ban were not immediately feasible, prioritising its prohibition.

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It finds that online gaming shows more documented terrorist financing activity than gambling, although proliferation financing risks remain limited across both sectors.

Cash, e-wallets, mobile money and virtual assets emerge as the payment methods most vulnerable to abuse. This is particularly true where operators use them to structure deposits below reporting thresholds. 

Giles Thomson, FATF president, said unregulated sectors risk becoming “attractive gateways for fraudsters, professional money launderers and organised criminal networks”. He called on governments to strengthen oversight, crack down on illegal and offshore operators and deepen public-private cooperation.