The European Union’s Anti-Money Laundering Authority (AMLA) has drafted new technical guidelines recommending that customer due diligence (CDD) be applied to gambling transactions reaching €2,000. This proposal, submitted in October, is intended to unify and strengthen anti-money laundering (AML) and counter-terrorism financing (CFT) measures across EU member states.
Draft Guidelines Aim for Greater Harmonisation
The draft report sets out technical standards for identifying criteria that indicate potential money laundering or illicit transactions. AMLA’s guidelines are designed to harmonise preventative measures across the EU, specifically targeting high-risk non-financial sectors such as gambling. The new €2,000 threshold aligns with existing EU AML legislation and is set to be retained in regulations applying from July 2027.
Implications for Operators and Regulators
For licensed operators, the guidelines mean that any transaction—whether stake, winnings, or both—reaching €2,000 will trigger mandatory due diligence checks. Several member states, including Sweden, France, Germany, and Spain, already enforce such checks. The guidelines also advise regulators and operators to consider a range of factors when assessing potentially linked transactions, such as shared digital infrastructure, coordinated activity, or multiple payments involving the same customer within a short period.
Importantly, the guidelines caution against treating any single criterion as decisive. Instead, operators must assess the broader commercial context to avoid false positives, which could arise from routine transactions or loyalty schemes.
Next Steps and National Responses
The Swedish Gambling Authority (Spelinspektionen) has publicly supported the guidelines, stating that they were developed collaboratively with national supervisors and informed by industry feedback. Spelinspektionen plans to implement the new standards for Swedish licensees starting 10 July 2027, pending final approval by the European Commission and publication in the EU’s Official Journal. AMLA has proposed a six-month transition period for businesses to comply after the rules come into effect.
Why This Matters for the Industry
The harmonisation of AML thresholds and procedures across the EU will create a more consistent regulatory environment for gambling operators and affiliates. This could simplify compliance for companies operating in multiple jurisdictions, but also requires them to update their systems and processes to meet stricter due diligence requirements. Regulators will gain clearer criteria for enforcement, while suppliers and affiliates must ensure their partners are prepared for the changes to avoid business disruption.
Key takeaways
- AMLA proposes a €2,000 due diligence threshold for gambling transactions across the EU.
- Guidelines aim to harmonise AML/CFT measures and clarify criteria for linked transactions.
- Sweden and other member states already apply similar checks; pan-EU adoption expected from July 2027.
- Operators must prepare for broader, context-based assessments to avoid false positives and ensure compliance.