Shifting Seas

How to play Shifting Seas

While it did not find Curaçao-based trust firm DECC and its directors liable in this case, the ruling signalled that closer scrutiny of such intermediaries could unfold.

Nederlandse Loterij has announced plans to appeal portions of the Lalabet decision, particularly arguing that trust firms have a duty to properly vet their clients. 

The operator was also investigating the roles of the same trust firm in relation to Qbet and Skyhills, indicating further legal proceedings may be forthcoming once corporate structures are clarified.

About Shifting Seas

The timing is significant. The illegal gambling market is attracting growing attention from regulators and the wider industry, while estimates of its size vary considerably depending on definitions and methodology.

A recent Fincord Intelligence report highlighted by the Betting and Gaming Council estimated that illegal online gambling generated around $50 billion in gross revenue globally in 2025. It estimated that around 5,000 operator structures were using more than 15,000 websites and apps.

Other estimates are considerably higher, illustrating how difficult the market is to measure. As an example, separate research from Gaming Compliance International put the value of unregulated online gambling at $5.9 trillion in wagering value in 2025, while estimating that unregulated operators accounted for 78% of global online gaming GGR.

What is Shifting Seas?

The decision to use a provisional measure means the restrictions can take effect immediately, less than a month before the elections. This is the clearest indication yet that the sector is being used for electoral purposes to try and secure Lula’s re-election.

The drafting of the text is reportedly in the hands of the Civil House, with some believing that it serves an electoral purpose, meaning Lula potentially riding the wave of criticism against the sector.

The Brazil betting industry has faced increasing scrutiny of late over claims that families are falling into debt because of gambling.