Debate over GGR in Sweden's money laundering fines

BOS, which represents Sweden's online gambling sector, has objected to the way administrative fines would be calculated during the consultation on incorporating the EU's new anti-money laundering package into national law. The consultation ends today, 30 October.

BOS said it generally welcomes the package. However, it opposed a proposal that the fine for an operator's Swedish activities be calculated on the total turnover of the whole group. According to the association, only Swedish turnover should be used, otherwise there is a risk of double punishment. The association also argues that fines should be calculated on gross gaming revenue. Players' winnings are customer money, so they do not belong to the operator. BOS says that of every 100 kronor wagered, about 95 kronor is paid out to players, and the penalty base should be the 5 kronor that remains with the operator. The association also points out that banks are penalized on their own turnover, and the total money in customer accounts is not the penalty base.

The debate is not new. In 2023, the Swedish Supreme Administrative Court ruled that penalty fees under the Gambling Act must be calculated on gross gaming revenue rather than total bets. The case concerned Genesis Global, which received a fine of SEK 4 million because it had not properly connected to Spelpaus, the national self-exclusion register. Until that ruling, the Swedish Gambling Authority (Spelinspektionen) had calculated fines on total bets.

In July, the Linköping Administrative Court upheld money laundering fines of SEK 6.5 million for Betsson Nordic, SEK 5.5 million for Snabbare and SEK 10 million for Spooniker, all imposed by Spelinspektionen. The issue therefore remains open.

The European Commission proposed the reforms in 2021, and the package was adopted in 2024. The new EU regulation will apply directly in all member states from 10 July 2027.