INTRODUCTION

 

This Financial Funds and Transactions Policy (“Policy”) defines the guidelines and rules applicable to deposits, withdrawals, and financial transactions in the systems of SABIÁ ADMINISTRAÇÃO LTDA (“Sabiá” or “Betting Operator”), operator of the BR4BET, Gol de Bet, and Lotogreen brands. This Policy was prepared based on current legislation and the rules issued by the Secretary of Prizes and Bets of the Ministry of Finance (“SPA/MF”), especially SPA/MF Normative Ordinance No. 615, of April 16, 2024 (“SPA/MF Ordinance No. 615/2024”). The procedures set forth herein take into account Sabiá's legal and regulatory status, in particular its status as a Betting Operator, pursuant to item II of Article 2 of SPA/MF Normative Ordinance No. 827, dated May 21, 2024 ("SPA/MF Ordinance No. 827/2024"), authorized to operate by SPA/MF until February 25, 2030, pursuant to SPA/MF Ordinance No. 399, dated February 24, 2025.

 

This Policy is updated and approved by Sabiá's administrators annually in order to verify its effectiveness and compliance with regulations, with a view to correcting any deficiencies identified. The documents proving the adoption and implementation of this Policy are kept available to SPA/MF.

  1. DEFINITIONS

 

To facilitate understanding of the guidelines presented, we have listed below the definitions of the main terms used in this document:

 

Betting Operator: legal entity authorized by SPA/MF to operate fixed-odds betting.

 

Bettor: Individual who places bets in accordance with the regulations.

 

Open Bet: a bet relating to a real sporting event or a virtual online gaming event that has not yet been financially settled by the Betting Operator;

 

Registered Account: a deposit or prepaid payment account owned by the bettor and verified by the Betting Operator, held at a financial or payment institution authorized to operate by the Central Bank of Brazil ("BCB"), used as the source of financial contributions and as the destination for prizes received and withdrawals of financial resources made by bettors with the Betting Operator;

 

Transactional Account: deposit or prepaid payment account owned by the Betting Operator, held at a financial or payment institution authorized to operate by the BCB, used as the destination for financial contributions made by bettors, to maintain the amounts related to open bets or, at the bettor's option, to maintain the prizes received;

Graphic Account: a virtual account, made available by the Betting Operator Agent in its betting system, which allows each bettor to manage their bets and financial resources;

 

PIX: instant payment system regulated by the Central Bank of Brazil, available 24 hours a day, 7 days a week (including holidays), which allows electronic transfers between accounts in seconds, via keys (CPF, CNPJ, email, cell phone, or random sequence) or traditional bank details;

 

KYC (Know Your Customer): Procedure for verifying the bettor's identity; and

 

AML/CFT: Anti-Money Laundering and Counter-Terrorist Financing.

  1. OBJECTIVE

 

This Policy is an integral part of Sabiá's governance structure and establishes the procedures to be followed, with a focus on security, transparency, traceability, and legal compliance for all transactions carried out by bettors.

 

The main purposes of this Policy are: 

 

  1. Ensure regulatory compliance: Ensure that all deposit, withdrawal, and financial transactions are fully aligned with the rules set forth in Law No. 14,790/2023, in the Ordinances of the Secretariat of Prizes and Bets of the Ministry of Finance (SPA/MF), and other regulations applicable to the activity of Betting Operator Agent;

 

  1. Protect the integrity of bettors' funds: Establish mechanisms to ensure that funds transferred, stored, or withdrawn are always linked to the verified account holder, reducing the risk of fraud, misappropriation, or asset confusion;

 

  1. Establish operational limits and control parameters: Set minimum and maximum amounts for deposits and withdrawals, define settlement deadlines and exception conditions, ensuring stable operation in line with best practices in the financial market and means of payment; and

 

  1. Promote traceability and transparency: Organize and standardize financial procedures so that all transactions can be audited, monitored, and properly justified, enabling accountability to the competent authorities.

 

  1. Mitigate operational and money laundering risks: Implement robust internal controls for identifying, verifying, and monitoring users and their transactions, preventing misuse of the platform for illicit purposes, including money laundering, terrorist financing, or concealment of funds of dubious origin;

4. FINANCIAL TRANSACTIONS

 

  1. DEPOSITS

 

Establishes the rules and procedures applicable to deposit transactions made by bettors on the Sabiá platform, intended for the Transactional Account, always for the purpose of placing bets. All transactions must comply with the principles of ownership, traceability, information security, and regulatory compliance, in accordance with current legislation.

 

Deposits to be made by Bettors must be made through PIX (the only method currently available), from the Bettor's Registered Account to the Betting Operator's Transactional Account, using the QR Code available on the Sabiá platform.

 

The minimum amount allowed per deposit is R$ 5.00 (five reais). There is no maximum limit per transaction or per day. As a rule, deposited amounts are automatically credited to the Graphic Account. However, in exceptional situations, such as systemic instabilities, the clearing period in the Graphic Account may be extended for up to 2 (two) hours.

 

Deposits made from an account other than the Registered Account, even if owned by the Bettor, will be automatically refused or reversed to the account of origin, and operating charges may be deducted.

 

In case of error or inconsistency in the deposit, the Bettor must immediately contact the Customer Service Center, presenting proof of the transaction. After analysis, the refund or regularization of the amount will be processed within 48 (forty-eight) business hours, except in cases where evidence of irregular activity is detected.

 

  1. WITHDRAWALS

 

Withdrawals can only be made to the Registered Account(s). Therefore, any transaction to third-party accounts is prohibited, even with the express authorization of the account holder or under any circumstances.

 

The minimum amount allowed for each withdrawal transaction is R$ 30.00 (thirty reais). If the available balance in the betting account is less than this amount, the withdrawal may be authorized for the full amount. There is no limit to the number of withdrawals that can be made per day.

 

If the sum of the Bettor's withdrawals made in the previous 24 hours exceeds R$ 50,000.00 (fifty thousand reais), checks must be applied in accordance with the PLD/FT Policy or related documents.

 

Withdrawals must be processed within 120 minutes of the Bettor's withdrawal request. If the withdrawal is not completed, the Bettor must contact the technical support of the Betting Operator Agent. If it is impossible to meet the deadline, Sabiá will keep documentation proving the cause of the delay, as required by regulation.

 

In situations involving suspected fraud, irregular activity, attempted systemic manipulation, or any behavior incompatible with Sabiá's internal rules, withdrawals may be suspended preventively until the investigation of the facts is completed, upon prior notification to the bettor's registered email address informing them of the block and the period of analysis. During this period, the amounts will remain blocked in a secure environment.

 

In cases of account closure due to the identification of a legal impediment (Centralized Self-Exclusion or Social Program Beneficiaries), the user will be duly notified and will have two (2) days to voluntarily withdraw the balance. After this period, Sabiá will process the mandatory return (remittance) of the funds to the registered account, in accordance with Articles 7 and 8 of IN SPA/MF No. 31/2025 and IN SPA/MF No. 22/2025.

 

5. MANAGEMENT OF GRAPHIC, TRANSACTIONAL, AND PROPRIETARY ACCOUNTS

 

Sabiá adopts a segregated account structure to ensure the security, traceability, and compliance of financial transactions, in accordance with SPA/MF Ordinance No. 615/2024. The following are the guidelines applicable to each type of account:

 

  1. GRAPHIC ACCOUNT

 

The Graphic Account is the virtual interface available on the Sabiá platform, where each bettor can consult and manage their bets and available financial resources. The following rules apply:

 

  • The Graphic Account must be unique for each brand operated by the Betting Operator Agent, and the consolidation of funds between different brands or the sharing of balances between platforms is prohibited;

 

  • The granting or promise of any form of remuneration, income, or financial advantage on the amounts held in the Graphic Account is prohibited; and

 

  • Sabiá must guarantee the bettor electronic access to the complete history of transactions in the Graphic Account for the last 36 (thirty-six) months, regardless of request, with the possibility of downloading in an accessible electronic format.

 

  • If the user identified as impeded has open bets, these will be canceled and the full amount wagered will be refunded to the graphic account for subsequent return, regardless of the outcome of the sporting event.

 

  • If it is not possible to return the funds (e.g., closed or non-existent bank account), Sabiá will keep the accounting record and attempt to contact the user. After 180 (one hundred and eighty) days from the closure notification, unclaimed amounts will be reverted to the Student Financing Fund (Fies) and the National Fund for Public Calamities (Funcap), ending the obligation to refund the bettor.

 

  1. TRANSACTIONAL ACCOUNT

 

The Transactional Account is a deposit or prepaid payment account owned by Sabiá, maintained at a financial or payment institution authorized to operate by the Central Bank of Brazil, intended for receiving bettors' contributions and maintaining the amounts related to open bets or, if the bettor so chooses, the prizes received. These funds are part of segregated assets, are not liable for Sabiá's obligations, and cannot be subject to judicial or extrajudicial constraints.

Sabiá may maintain multiple Transaction Accounts at different financial institutions for the purposes of managing liquidity risk and ensuring the integrity of bettors' funds.

 

  1. OWNER ACCOUNT

 

The Proprietary Account is a deposit or prepaid payment account owned and freely managed by Sabiá, held at a financial or payment institution authorized to operate by the Central Bank of Brazil, used to cover operating expenses and manage liquidity, in accordance with the internal controls and asset segregation provided for in the applicable regulations. 

 

 

6. FEES AND CHARGES

 

Sabiá does not charge any administrative or operating fees for deposits or withdrawals made by bettors on the platform, seeking to ensure barrier-free access to the basic features of the system. However, any charges applied to deposit or withdrawal transactions by financial or payment institutions, as well as operating costs related to chargebacks, payment rejections, or financial disputes, may be deducted from the Bettor's balance.

 

7. MONEY LAUNDERING PREVENTION 

 

Sabiá adopts strict internal controls and has its own policy that defines the procedures for the prevention of Money Laundering and Terrorist Financing (PLD/FT), in accordance with SPA/MF Ordinance No. 1,143/2024 and other applicable regulations. All transactions carried out on the platform are continuously monitored, and additional documentation may be required at any time to verify the bettor's identity or the origin of the funds.

 

Transactions with signs of irregularity are analyzed according to criteria established in the AML/CFT policy and, when necessary, confidentially reported to the competent authorities, such as COAF and the Federal Revenue Service. These measures aim to ensure the integrity of operations and compliance with regulatory requirements.

 

8. BONUSES

 

Withdrawals linked to promotional bonuses will be conditional upon full compliance with the bonus release rules, as set out in the Terms and Conditions of Promotions, with the following being prohibited: (i) the offer of bonuses upon prior financial contribution and (ii) the conditioning of withdrawals on the placing of new bets by bettors.

 

9. SUPPORT

 

Sabiá provides a Customer Service Center, prepared to provide support related to financial transactions, accessible through the platform's official channels. The service is provided by a trained team, qualified to guide bettors on operational procedures and appropriate corrective measures.

In the event of failures in the processing of deposits or withdrawals, inconsistencies in amounts, operational questions, or suspicion of irregular activities, the bettor must immediately contact Sabiá, presenting, whenever possible, supporting documentation (such as transaction receipts, screen prints, or other relevant records). The initial response time may vary depending on the complexity of the request, subject to the maximum time limit set forth in this Policy, unless there is a justified reason.

 

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