BOS asks that EU AML gambling fines be based on Swedish GGR
BOS seeks proportional sanctions tied to operator revenue in Sweden, not group turnover
Key Takeaways
- BOS asked the Ministry of Finance of Sweden on 30 October 2026 that EU AML administrative fines be based on Swedish GGR and not on group turnover.
- The association argues that using group turnover risks double punishment and would conflict with Swedish and EU law.
- BOS proposes calculating fines on the operator's retained remainder: typically 5 kronor of every 100 wagered, defined as GGR.
- Gustaf Hoffstedt, BOS Secretary General, said the association supports the EU AML package but requests changes to ensure proportionality in sanctions.
The Swedish Trade Association for Online Gambling (BOS) asked the Ministry of Finance of Sweden on 30 October 2026 that administrative fines under the European Union's anti-money laundering (AML) package be calculated on the Gross Gaming Revenue (GGR) generated in Sweden and not on a group's total turnover. BOS supports the EU initiative but disputes the proposed method for computing sanctions.
Main objection from BOS
BOS objects to the proposal that the tax base for fines be the total turnover of a gambling group across all its operations. The association argues that penalties related to compliance in Sweden should be calculated on the turnover of the operator within Sweden. It says using group turnover creates "clear risks of double punishment" and would conflict with Swedish and EU law.
Why they propose using GGR
The association explains that bets returned to players are client funds and do not belong to operators. BOS proposes that sanctions be based on GGR—the funds remaining after prize payments—instead of stakes or gross turnover. To illustrate its calculation, BOS says that for every 100 kronor wagered, typically 95 kronor are returned to customers as winnings and the operator retains 5 kronor; that remainder of 5 kronor should be the base for fines. BOS likens this approach to banking practice, where fines are calculated on the bank's own revenue rather than on total customer deposits.
"BOS welcomes the EU's anti-money laundering package. It has the potential to be an important tool in the fight against money laundering. At the same time, some areas—particularly administrative fines—need to be rethought to ensure proportionality, avoid double punishment and promote legal certainty overall," said Gustaf Hoffstedt, Secretary General of the Swedish Trade Association for Online Gambling.
Submission to the Swedish authority
The document was submitted to the Swedish Ministry of Finance on 30 October 2026 as part of the consultation on the EU AML package. BOS maintains its support for the package, subject to a review of the method for calculating sanctions for operators active in Sweden. For regulatory context, see regulation.
Frequently Asked Questions
What did BOS specifically request from the Ministry of Finance of Sweden?
BOS requested on 30 October 2026 that administrative fines under the EU AML package be calculated on the Gross Gaming Revenue (GGR) generated in Sweden rather than on the gambling group's total turnover.
Why does BOS reject using group turnover to set fines?
BOS says using group turnover would create "clear risks of double punishment" and would be contrary to Swedish and EU rules; it argues fines related to Sweden should reflect the operator's turnover within Sweden.
How does BOS propose fines should be calculated instead?
BOS proposes basing fines on Gross Gaming Revenue (GGR), the funds remaining after prize payments. They give an example that for every 100 kronor wagered, typically 95 kronor are returned to players and 5 kronor remain as GGR, and that remainder should be the basis for sanctions.
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About the author
Miguel Sandoval
Regulatory Affairs Correspondent
Miguel Sandoval tracks gambling legislation, licensing, and regulator enforcement — from Spain's DGOJ and the Latin American authorities to the UKGC, the MGA, and the state-by-state map in North America. The reports answer three questions precisely — what changed, where, and who it affects — with jurisdictions, dates, and penalties cited exactly as published. Operators and compliance officers read Miguel Sandoval to know which rulebook moved before their next meeting.
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