The Swedish online gambling association Branschföreningen för Onlinespel (BOS) spoke out on 30 October, the day the Finance Ministry's consultation closed, against calculating AML fines from the turnover of an entire group of companies. In its view, fines for activity in Sweden should be based only on Swedish turnover and gross gaming revenue (GGR).
In July, the Swedish Finance Ministry published a memorandum on how to adapt national law to the EU's AML package. The new EU anti-money laundering regulation will apply directly in all member states from 10 July 2027. BOS broadly supported the measures but objected to counting the whole group's turnover. The association said this creates "clear risks of double punishment" that contradict Swedish and EU law.
The second demand concerns the base for the calculation. BOS argues that winnings belong to customers, not the operator, so the fine should be calculated on what remains after payouts. As an example, the association cited a typical ratio: of every 100 kronor in bets, about 95 goes back to players and the operator keeps 5. It compared this to bank fines, which are calculated on the bank's own turnover rather than on the sums in customers' accounts.
BOS Secretary General Gustav Hoffstedt called the package a potentially important tool against money laundering, but said administrative fines need revisiting to ensure proportionality and legal certainty.
BOS is not the first to raise this argument. In 2023, the Supreme Administrative Court of Sweden ruled that fines under the Gambling Act must be calculated from GGR, not total turnover. The case involved Genesis Global, which was fined 4 million kronor for incorrectly connecting to the national self-exclusion register Spelpaus. Before that, the regulator Spelinspektionen had calculated fines from the amount of bets.
The question remains live. In July, the administrative court in Linköping upheld Spelinspektionen's AML fines: 6.5 million kronor for Betsson Nordic, 5.5 million for Snabbare and 10 million for Spooniker.
The final wording of Swedish rules depends on the outcome of the consultation; the documents available today give no timeline for the next step.
