Regulation

BOS wants AML fines based on Swedish GGR

By Johan Ekström · Published 30 October 2026

Branschföreningen för Onlinespel, BOS, has submitted its response to Sweden’s Ministry of Finance on the EU’s anti-money laundering package. The consultation deadline closed on 30 October 2026. BOS broadly backs the package, but raises concerns about how fines for money laundering breaches should be calculated.

The trade body specifically flags the risk of fines being based on a group’s entire turnover rather than the Swedish part of the business.

What has changed

The Ministry of Finance invited BOS and other bodies to comment on the EU-wide framework against money laundering. The trade body has called for a rethink of how AML fines are calculated, as a government consultation on implementing new EU AML rules closes on the same day. BOS broadly welcomed the measures.

The problem, according to the association, is that fines risk being calculated on a company’s entire global turnover rather than the part of the business tied to Sweden. The association says fines tied to Swedish compliance should be based on the operator’s turnover within Sweden, warning that using group-wide turnover creates clear risks of double punishment that would run counter to Swedish and EU law.

BOS also wants sanctions calculated using gross gaming revenue, the money left after winnings have been paid out, rather than stakes or broader turnover measures. The association argues that fines should be calculated on gross gaming revenue, meaning the money left after winnings have been paid out. This mirrors an argument BOS has made before. In 2023, Sweden’s Supreme Administrative Court ruled that penalty fees under the Gambling Act must be based on GGR rather than total turnover.

What it means for you

For players, the consultation response doesn’t change how checks work today. Licensed operators must still carry out customer due diligence and verify the source of funds, regardless of how future fines are calculated. The debate is about how hard a company is punished financially if it fails, not about whether you face more or fewer checks when you deposit.

What could indirectly affect you is how financially stable licence holders remain. Past AML cases have shown that large fines can hit several brands under the same licence at once. Flutter and Betsson were fined SEK 13.5m each over failings at subsidiary brands, tied to AML breaches in Sweden. Snabbare, which has been ComeOn’s dedicated Swedish brand since 2017 under a dual Swedish and Maltese licence, was also fined in a similar case. If you hold an account with a company hit by a large fine, it can therefore affect several sister sites at once, since brands often share the same licence.

Whatever rules end up applying, the basic protections remain the same: you can always exclude yourself from all licensed gambling via Spelpaus, and support is available through Stödlinjen if gambling becomes hard to control.

The bigger picture

BOS has long argued that fines should reflect what a gambling company can actually afford to pay, not sums that effectively belong to players. The association supported the earlier plan but said AML fines should also be based on GGR, arguing it was unreasonable for penalties to be paid from money that belongs to players. The argument builds on the 2023 ruling, which already forced the regulator to rethink how penalty fees are calculated once before.

The fight over fine levels has been a recurring theme in Swedish gambling regulation since the 2019 re-regulation. Meanwhile, several other processes are under way concerning how strictly operators should be scrutinised, including tighter EU-level anti-money laundering requirements. How the government ultimately settles the turnover question could affect how large future sanctions are for Swedish licence holders such as Betsson and ComeOn Group.