Spelinspektionen Opposes Proposed Changes to Sweden’s AML Law.
Spelinspektionen, Sweden’s gambling regulator, has raised concerns about parts of the government’s proposed overhaul of the country’s anti-money laundering (AML) law. It warns that the changes could remove one of its enforcement tools and add to its workload before the EU’s new rules take effect on 10 July 2027.
The authority outlined its views in a consultation response published on 27 October. The response addresses a Ministry of Finance memorandum on the EU anti-money laundering package (Fi2026/01654), released in July. The memorandum sets out how Sweden could align its laws with the EU’s new AML regulation and the Anti-Money Laundering Authority (AMLA), established under the package.
Spelinspektionen broadly supports the proposals but opposes two measures and says several others need clarification. Its board adopted the response, which was signed by Director-General Peter Knutsson.
Concerns over enforcement powers and lottery oversight
Spelinspektionen’s primary objection is to a proposal preventing supervisors from attaching a conditional fine, known as vite, to orders requiring companies to provide information and documents for inspections. The memorandum suggests relying instead on sanction fees and other administrative measures.
The regulator argues that these measures serve different purposes. A conditional fine is intended to make a company “actually provide the material needed for supervision”, it wrote. Without that material, a supervisor “cannot assess whether the business complies with the anti-money laundering rules” (translated from Swedish).
Under chapter 19, section 16 of the Gambling Act, Spelinspektionen may already charge licensees a fee for late submissions. However, this applies only to information requested under the Gambling Act. The authority says it would lack a similar option in AML cases if conditional fines were not permitted.
The second objection concerns registration lotteries. Under the memorandum, Spelinspektionen would assess organisers’ suitability and supervise them. The regulator believes municipalities should retain this responsibility, as they already handle applications under the Gambling Act. It also says the proposed change could mean applicants often small non-profit associations would have to deal with two authorities.
Questions about fees and reporting deadlines
Spelinspektionen supports allowing sanction fees for gambling companies to reach 10% of turnover. However, it points out that AMLA’s draft technical standard sets a minimum range of 0.4% to 0.8% of turnover for the most serious violations. The regulator questions whether, in practice, it could impose penalties close to the proposed 10% limit.
It also highlights a potential conflict between reporting deadlines. The proposed AML law would require companies to report changes to management or beneficial ownership “as soon as possible”, while the Gambling Act allows licensees 14 days. Spelinspektionen considers the 14-day period reasonable and wants it to satisfy both requirements.
The authority is also seeking clearer rules on which body would supervise non-financial holding companies that own gambling operators in multiple countries. In addition, it wants a transitional provision to ensure existing AML exemptions for certain gambling services remain in force after 10 July 2027.
Request for additional funding
Spelinspektionen estimates that it will need SEK 5 million in one-off funding in 2027, including SEK 2 million for IT. From 2028, it is requesting SEK 3 million annually to maintain IT systems and fund two additional staff members for coordination and supervision.
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The regulator says the memorandum underestimates the work involved in applying AMLA’s standards and guidelines. Without additional funding, it warns, staff would have to be reassigned from other duties, with licensing taking priority over supervision including oversight under the Gambling Act and action against illegal gambling.
Spelinspektionen also points to a 2024 report by the Swedish National Audit Office (RiR 2024:19), which found that its supervision was not effective enough, largely because it conducted too few inspections. Recent regulatory decisions include the ban on Duel.com’s operator. More decisions are listed on the Spelinspektionen tag page.
What happens next?
The consultation responses will now return to the Ministry of Finance, which prepared the memorandum. Until 10 July 2027, Spelinspektionen will continue supervising gambling companies under the current AML law. From that date, the EU regulation, Sweden’s new law and AMLA’s technical standards are due to apply.
