BOS urges EU to calculate AML gambling fines on Swedish GGR, not group turnover
Swedish trade body told Sweden’s Ministry of Finance fines should use domestic GGR to avoid double punishment.
Key Takeaways
- BOS submitted views to Sweden's Ministry of Finance on 30 October 2026 about the EU AML package.
- BOS opposed using a gambling group's total turnover to calculate fines for activities in Sweden.
- The association argues fines should be based on Gross Gaming Revenue (GGR), not stakes or customer deposits.
- BOS illustrated that for every 100 kronor wagered, typically 95 kronor is returned to customers and the operator retains 5 kronor.
The Swedish Trade Association for Online Gambling (BOS) told Sweden’s Ministry of Finance on 30 October 2026 that the EU’s proposed anti-money laundering package should base administrative fines for gambling on Swedish Gross Gaming Revenue (GGR), not the total turnover of a gambling group. BOS backed the EU initiative generally but argued the current draft creates "clear risks of double punishment" and undermines proportionality and legal certainty.
BOS submission to the Ministry of Finance
BOS objects to a proposal in the EU AML package that would use the total turnover of an entire gambling group as the basis for administrative fines linked to an operator’s activities in Sweden. The association said fines tied to Swedish compliance should instead be calculated on the operator’s turnover within Sweden, and ultimately on GGR — the funds remaining after winnings are paid to players.
"BOS welcomes the proposed EU anti-money laundering package. It has the potential to become an important tool in the fight against money laundering. At the same time, a rethink is needed in some areas — particularly regarding administrative fines — to ensure proportionality, avoid double punishment, and promote legal certainty in general," said Gustaf Hoffstedt, Secretary General of the Swedish Trade Association for Online Gambling.
GGR versus stakes or group turnover
BOS argued that winnings are client funds and "do not belong to the gambling operators," so stakes or broader turnover measures are inappropriate bases for sanctions. To illustrate the point, BOS gave a concrete example: for every 100 kronor wagered, typically 95 kronor is returned to customers as winnings while the operator retains 5 kronor. BOS said that retained funds — the operator's GGR — should be the basis for administrative fines.
Analogy and legal point
BOS compared the treatment to banks, where fines are based on the bank's own turnover rather than the total balance of customer deposits. The trade body urged the Ministry of Finance to press for revisions in the AML draft to avoid outcomes it says would run counter to Swedish and EU law. For further regulatory context, see regulation.
Frequently Asked Questions
What did BOS ask Sweden's Ministry of Finance regarding the EU AML package?
BOS asked the Ministry of Finance to ensure administrative fines for gambling in Sweden are based on Swedish turnover and Gross Gaming Revenue (GGR), not the total turnover of the gambling group's global operations. The submission was made on 30 October 2026 and described the group-turnover approach as creating "clear risks of double punishment."
Why does BOS prefer GGR as the basis for fines?
BOS prefers GGR because it represents the operator's retained funds after winnings are paid to players. The association gave the example that for every 100 kronor wagered, typically 95 kronor is returned to customers as winnings and the operator retains 5 kronor, which it says should be the basis for sanctions.
What legal comparison did BOS use to support its position?
BOS compared gambling fines to banking practice, noting that banks are fined based on the bank's own turnover rather than customer deposit balances. The trade body used this analogy to argue for proportionality and legal certainty under Swedish and EU law.
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About the author
Eleanor Whitfield
Regulatory Affairs Correspondent
Eleanor Whitfield tracks gambling legislation, licensing decisions, and regulator enforcement across key markets — from the UKGC, MGA, and Germany's GGL to Spain's DGOJ and the state-by-state map in the Americas. The reporting answers three questions precisely: what changed, where, and who it affects, with jurisdictions, effective dates, and penalty figures named exactly as published. Compliance officers and operators read Eleanor Whitfield to know which rulebook moved before their next board meeting.
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