BOS Review Highlights Spelinspektionen's Punitive Enforcement Compared to Peer Swedish Regulators
A BOS-commissioned Nordic Legal review finds Spelinspektionen prioritizes punishment in AML cases via small customer file samples and penalties often exceeding 50% of maximums. This contrasts with the system-wide, lower-percentage sanction approach of FI and other Swedish regulators. The critique fuels calls for more dialogue-focused supervision in the licensed gambling market.
SCCG Take — Regulators risk undermining licensed operators through disproportionate penalties that overlook systemic controls, pointing to a need for consistent cross-agency standards to improve actual compliance outcomes.
A legal review commissioned by the Swedish Trade Association for Online Gambling (BOS) concludes that Spelinspektionen adopts a tougher and more punitive supervisory approach than other Swedish authorities. Prepared by law firm Nordic Legal, the report examines differences in AML oversight, sanction levels, and suitability assessments. It argues for greater alignment with practices that favor regulatory dialogue over immediate penalties.
The review compares Spelinspektionen with the Swedish Financial Supervisory Authority (FI), the Schools Inspectorate (SSI), and the Stockholm County Administrative Board. Those bodies generally apply a risk-based, system-wide approach to AML compliance. They evaluate an organisation's overall risk framework, policies, and internal controls before turning to customer records for testing.
AML Investigation Methods
Spelinspektionen often centers AML investigations on small samples of customer accounts rather than broader systems. The report reviewed 12 AML enforcement decisions issued since 2021. It found that 11 of them relied primarily on examinations of between five and 15 customer files, with limited weight given to operators' full risk assessments and AML policies.
Scale of Financial Penalties
Sanctions imposed by Spelinspektionen also tend to be higher relative to statutory maximums. Among nine AML enforcement decisions examined between 2022 and 2025, seven resulted in sanctions amounting to at least 50 per cent of the maximum penalty available under the law, including two that reached approximately 91 per cent and 100 per cent of the statutory maximum. By comparison, FI's AML fines in major banking cases generally represented between 20 per cent and 27 per cent of its maximum available sanction.
Gustaf Hoffstedt, Secretary General of BOS, said: “We believe the licensed gambling market in Sweden would benefit if the Swedish Gambling Authority were to adopt working methods more closely aligned with those of other Swedish government agencies.” The findings, as reported by Focus Gaming News, surface amid continued enforcement, including a recent SEK40m penalty upheld against bet365 for customer protection breaches from 2019 to 2022. The industry maintains that a more collaborative model would support compliance without diminishing standards.
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