BOS warns Sweden’s AML fine plans risk “double punishment” for operators

Swedish trade body Branschföreningen för Onlinespel (BOS) wants AML penalties calculated on Swedish gross gaming revenue (GGR), not on group-wide turnover or total stakes. The timing matters: Sweden’s consultation on implementing the EU AML package closes today, and the rules will start applying directly across EU member states from 10 July 2027.

1. BOS broadly supports the new EU anti-money laundering package, which the Ministry of Finance set out in a memorandum in July. But it objects to one part of the Swedish approach: the idea that fines for conduct in Sweden could be based on the turnover of an operator’s entire group, rather than only the Swedish business.
2. The association says sanctions should be tied to Swedish turnover only. Its argument is that using group-wide figures “creates clear risks of double punishment which runs counter to both Swedish and EU law”. For operators with cross-border structures, that is not a theoretical complaint; it is a direct question of what part of the corporate stack the state can reach when it calculates a penalty.
3. BOS also wants fines to be based on GGR, meaning the amount left after player winnings are paid out. In its view, winnings are client funds, not operator revenue. Its example is simple: if a player wagers SEK100, around SEK95 is typically returned and the operator keeps SEK5. BOS says that SEK5, not the full SEK100, should form the basis for any penalty.
4. That position mirrors how BOS says banks are fined: on the bank’s own turnover, not on the total amount held in customer accounts. Gustaf Hoffstedt, BOS secretary general, said the trade body welcomes the EU AML package and sees it as “an important tool in the fight against money laundering”, but added that administrative fines need a rethink to preserve proportionality, avoid double punishment and promote legal certainty.
5. This is not a new fight. In 2023, Sweden’s Supreme Administrative Court ruled that penalty fees under the Gambling Act must be based on GGR rather than total turnover. The case involved Genesis Global, which was fined SEK4 million for failing to connect properly to the national self-exclusion register, Spelpaus. Until then, regulator Spelinspektionen had calculated fines on total stakes.

The issue is still active in Sweden’s enforcement pipeline. In July, the Administrative Court in Linköping upheld Spelinspektionen’s AML fines of SEK6.5 million against Betsson Nordic, SEK5.5 million against Snabbare and SEK10 million against Spooniker. For operators and their payment partners, the practical question is straightforward: if Sweden keeps using group-level or stake-level numbers for AML penalties, the sanction base can become much larger than the revenue actually earned in the local market.