Spelinspektionen Repeals Previous Exemption Following Elevated Risk Assessment for Brick-and-Mortar Venues
The Swedish Gambling Authority (Spelinspektionen) has enacted formal amendments to its anti-money laundering and counter-terrorist financing regulations (SIFS 2019:2), officially bringing land-based commercial casino gaming under the scope of Swedish AML laws effective September 1, 2026. The regulatory shift repeals a longstanding exemption previously granted to brick-and-mortar operators under Chapter 9 of the Gambling Act.
The decision stems from an updated national risk assessment in which Spelinspektionen concluded that the exposure of land-based commercial casino operations to illicit financial flows can no longer be classified as low risk.
Mandatory Risk-Based Approach for Licensees
Operators holding licenses for commercial land-based gaming must immediately audit and update their operational compliance frameworks to align with the revised guidelines. Licensees are mandated to implement an active, risk-based strategy capable of detecting, analyzing, and preventing financial crime.
Under the updated regulatory framework, land-based operators must:
- Conduct General Risk Assessments: Formulate comprehensive organizational risk profiles that reflect variable and evolving exposure to financial crime.
- Customer Due Diligence (CDD): Establish clear “Know Your Customer” protocols and evaluate individual player risk profiles.
- Internal Procedures & Guidelines: Institute and enforce formal operating manuals and compliance protocols.
- Staff Training: Implement continuous training programs to ensure venue personnel recognize suspicious activity and regulatory obligations.
- Ongoing Monitoring: Deploy operational routines for continuous transaction and behavioral monitoring on gaming floors.
Spelinspektionen emphasized that a risk-based model requires operators to deploy more comprehensive safeguards where exposure is determined to be higher, ensuring resources are distributed proportionately to actual operational vulnerabilities.
Player Registration Nuance and Upcoming EU Framework
While land-based commercial casinos remain exempt from mandatory player registration under the general provisions of the Gambling Act (Section 2 SIFS 2022:2), Spelinspektionen noted that this relief does not override the Money Laundering Act. Operators may still be required to identify and record customer details through alternative compliance mechanisms to fulfill statutory due diligence thresholds.
The regulatory tightening in Sweden arrives ahead of a broader overhaul of European financial crime legislation set to take effect on July 10, 2027. Led by the newly established European Anti-Money Laundering Authority (AMLA), the unified EU framework will feature the directly applicable Anti-Money Laundering Regulation (AMLR) and the Sixth Anti-Money Laundering Directive (AMLD6), replacing the Fourth AML Directive across all member states.
