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Brazil has taken yet another step towards further consolidating its betting and lottery regulatory regime. On January 28th, the Secretariat of Prizes and Bets of the Ministry of Finance (SPA/MF) officially established the National Forum for Systematization of Bets (SINAPO), an institutional mechanism that seeks to bring greater harmony to betting rules and practices in Brazil. This move has been formalized by Ordinance SPA/MF No. 227, published in the Federal Official Gazette on January 29th.
The SPA’s creation of SINAPO represents yet another of Regis Anderson Dudena’s final steps as head of the SPA. In conjunction with this move, on January 29th, Dudena was also appointed to the position of Secretary of Economic Reforms at the Ministry of Finance, thus closing a cycle characterized by the structuring of Brazil’s regulated betting industry.
Objective: Unified Rules and Legal Certainty
SINAPO’s creation was motivated by a need to “articulate, integrate, and promote dialogue between the Union, the States, and the Federal District in regard to the operation of lottery modalities.” In other words, SINAPO’s objective is to bring greater harmony to rules in an industry in which Brazil’s constitution allows for state lotteries to operate in conjunction with federal oversight.
The key objectives of SINAPO’s work are to exchange best practices in regard to rules and operations, coordinate joint actions, integrate strategic data, and enhance legal certainty, transparency, and integrity, particularly in regard to betting operations and the popular economy.
The SPA’s intention in creating an institutional environment in which SINAPO will operate is to reduce fragmentation in rules and enhance legal certainty for both operators and regulators.
Structure and Governance of SINAPO
SINAPO will be coordinated by the SPA and will comprise representatives from the Federal Government, the States, and the Federal District. The SPA will be represented by its Secretary, who will be the principal representative, and by its Deputy Secretary, who will be the alternate representative.
States and the Federal District may adhere to SINAPO by signing an adhesion term, which will determine the respective rights and duties. The SPA will have a maximum of 45 days to make this adhesion term available.
It is clear from the ordinance that SINAPO will not have a minimum number of members to congregate and deliberate, and that it will have non-binding and non-deliberative outcomes, which reinforces its consultative and coordinative role and not its supervisory role.
Meetings and Thematic Working Groups
It is anticipated that SINAPO will meet four times a year on a regular basis, and extraordinary meetings will take place when deemed necessary. The meetings may take place physically, virtually, or in a combination of both. The participation of members will be restricted to formally designated representatives, although the SPA may, if deemed appropriate, invite other public entities, private entities, and civil society representatives to attend the meetings.
Moreover, it is contemplated that a maximum of five Thematic Debate Forums may be created, which will have a duration of three months and may be renewed for the same period. These working groups will have the objective of discussing specific issues concerning the operation of lotteries and bets and will complement the SINAPO meetings.
A Symbolic Closing Act for Dudena’s Tenure
The creation of SINAPO serves to consolidate Dudena’s legacy in his time at the SPA, in which he was instrumental in designing Brazil’s betting regulation through decrees, ordinances, and operational frameworks. The creation of this national forum, which emphasizes coordination over centralization, is therefore significant in its demonstration of the Ministry of Finance’s cooperative approach to betting regulation in Brazil.
As Dudena takes up his new position, SINAPO represents a strategic tool designed to promote regulatory consistency, dialogue between the federative entities, and the sustainability of Brazil’s betting and lottery system.
Source: iGaming Brasil
