The Swedish Trade Association for Online Gambling (BOS) claims that the Swedish Gambling Authority takes a stricter approach to supervision and penalties than other Swedish regulators. According to a BOS report, this was seen in anti-money laundering checks and assessments of casino operators’ owners and management.
Titled Under Scrutiny: The Swedish Gambling Authority compared with other Swedish authorities, the report compares the regulator’s practices with those of the Swedish Financial Supervisory Authority (FI), the Stockholm County Administrative Board in Stockholm (Lst Stockholm) and the Swedish Schools Inspectorate.
The analysis focuses on three areas: anti-money laundering supervision, suitability assessments of owners and management, and financial penalties. The report cautions that the authorities operate under different mandates and regulatory frameworks, but it identifies recurring contrasts in their supervisory methods and enforcement actions.
“The material reveals recurring differences in how the Swedish Gambling Authority conducts supervision in the areas where a direct comparison is possible,” the report states.
AML Supervision Focuses on Individual Customer Files
A key focus of the report is how the Authority reviews compliance with anti-money laundering protocols.
It found that in 11 of the 12 AML decisions reviewed since 2021, the regulator based its assessment primarily on a limited sample of individual customer files, typically between five and 15. These files were usually selected from customers with the highest deposits or based on their young age.
In comparison, FI reviews companies’ overall risk assessments, policies and procedures, based on customer files to illustrate how those systems work in practice. Lst Stockholm also relies on business-wide risk assessments and internal procedures.
Still, Nordic Legal argues that the gambling regulator’s model places greater emphasis on individual cases than on the wider systems operators use to identify and mitigate money laundering risks.
But the report doesn’t conclude that such a methodology is unregulated. Instead, it notes that Swedish administrative courts have accepted that faults found through customer samples can establish serious infringements, while finding that limited samples alone may not demonstrate that the deficiencies are systematic.
The Betsson Nordic case is an example of the issue. SGA reviewed 10 customer files and imposed a SEK 6.5 million sanction fee, finding serious deficiencies in the operator’s AML work.
Afterwards, the Administrative Court concluded that the infringements were serious but that the limited sample was insufficient to establish that they were systematic. The judgment was appealed to the Administrative Court of Appeal in Jönköping.
Late Notifications Trigger Action Against Casinos
The report also identifies differences in how authorities assess changes in company ownership and management.
Since the introduction of the Swedish Gambling Act, the Authority has issued decisions on 36 Swedish casinos regarding compliance with notification requirements for owners and management. All of these decisions were announced in 2025 and 2026.
Of those operators, 19 received warnings and sanction fees, while 12 received comments and sanction fees. Five cases were closed without further action since no changes had been made without prior notification.
Importantly, the report determined that in every case that led to enforcement action, the infringement involved a failure to notify changes in ownership within the set deadline. In all cases, the people concerned were henceforth found suitable for their positions.
The comparison found that authorities took a different approach. The Swedish Schools Inspectorate focused on whether owners and managers possessed the necessary knowledge, with measures including orders to address errors, management changes and, in serious cases, withdrawal of approval.
Nordic Legal found no comparable cases in which FI or the Schools Inspectorate imposed sanctions solely because changes had been reported late.
Therefore, the report argues that the gambling watchdog’s approach places greater weight on administrative compliance than on whether the individuals involved actually meet the legal suitability requirements.
SGA’s Fines Closer to Statutory Maximums
The report’s third major finding is about financial penalties imposed for AML breaches.
Instead of comparing fines in absolute terms, Nordic Legal assessed them as a proportion of the maximum amount each authority was legally entitled to impose, which reflects differences in the size of supervised businesses and the applicable legal frameworks.
Of nine published AML decisions issued by the Authority between 2022 and 2025, seven resulted in fines amounting to at least 50% of the applicable maximum. Two penalties reached approximately 91% and 100% of the maximum, respectively.
The examples included a SEK 10.9 million fine against Spooniker Ltd in 2022, equivalent to the full maximum then applicable, and a SEK 10 million fine against the operator in 2025, representing approximately 91% of the maximum.
By contrast, the report found that FI’s penalties in the cases examined generally represented around 20% to 27% of the applicable maximum in major banking cases, while Lst Stockholm typically imposed a smaller proportion of its available sanctioning range.
Findings do not establish that the Authority’s penalties are normally disproportionate. However, the report concludes that the regulator has regularly used a greater proportion of its available sanctioning powers in the AML cases reviewed.
The report also raises concerns about transparency and predictability, and argues that gambling operators may struggle to anticipate penalties when regulatory decisions do not clearly explain how individual circumstances have influenced the amount imposed.
Seeking Dialogue on Proportionality
Despite its findings, Nordic Legal cautions against drawing broad conclusions about the overall quality or effectiveness of authorities. Their mandates, the entities they supervise and the relevant legal frameworks differ, limiting the scope for direct comparisons.
The report instead argues that the differences identified warrant further discussion about the design and proportionality of regulatory supervision in Sweden.
Its conclusions broadly support the gambling industry’s perception that the Swedish Gambling Authority is more formalistic and sanction-oriented than other Swedish regulators in the areas examined.
“What the comparison does show is that authorities with similar supervisory mandates, and, in the AML area, to a significant extent the same legal starting points, have developed different ways of conducting supervision and using their enforcement powers.”
Commissioned by BOS, the study is intended to provide policymakers and stakeholders with a foundation for examining how the Gambling Authority supervises licensed operators and whether its enforcement practices could be made more transparent and proportionate.
