Swedish online gambling trade association Branschföreningen för Onlinespel (BOS) has urged Sweden's government to reconsider how administrative fines for gambling operators are calculated under the European Union's anti-money laundering (AML) package. BOS expressed concerns that the current approach could lead to disproportionate sanctions and the risk of double punishment for operators.
BOS Responds to AMLA Consultation
BOS submitted its feedback after Sweden's Ministry of Finance sought input on new AML guidelines and technical recommendations proposed for EU member states by the EU Anti-Money Laundering Authority (AMLA). While BOS supports the overarching goals of the AML package, the association objects to specific sanctioning mechanisms outlined in the wider EU framework.
Concerns Over Penalty Calculations
BOS is particularly critical of using an entire gambling group's turnover—including revenue from outside Sweden—to calculate penalties for breaches related to Swedish operations. The association argues that such an approach could lead to operators being fined for activity not connected to the Swedish market, potentially resulting in double penalties. BOS also objects to including money returned to players as winnings in the calculation base, stating that only the revenue operators actually retain—gross gaming revenue (GGR)—should be used when determining fines.
Why This Matters for the Industry
The way administrative fines are calculated has significant implications for gambling operators active in Sweden. If fines are based on global turnover or include customer winnings, operators could face much higher penalties for local breaches, potentially impacting their willingness to operate in the market. BOS's call for fines to be based solely on Swedish GGR aims to ensure penalties remain proportionate and legally certain, helping to maintain a fair regulatory environment for both operators and affiliates.
Key takeaways
- BOS urges Sweden to review how fines are calculated under the EU AML package.
- The association wants penalties based on Swedish gross gaming revenue, not global turnover.
- Concerns include the risk of disproportionate sanctions and double punishment.
- Changes could affect how operators and affiliates approach compliance in Sweden.