BOS, the Swedish trade association for online gambling, has submitted its response to a public consultation led by the EU’s new Anti-Money Laundering Authority (AMLA).
The request for consultation was about RTS (Regulatory Technical Standards) and related to proposed rules around sanctions, administrative measures and fines for AML breaches.
The consultation and the new rules are an attempt to harmonise how supervisory authorities across EU member states classify breaches of AML rules and determine appropriate sanctions.
In its response, BOS said the proposed indicators for assessing the seriousness of breaches should be applied cautiously to gambling operators, noting the sector’s limited direct exposure to the financial system compared with banks or financial institutions.
The association argued that certain criteria – such as assessing the “impact on financial markets” – may be difficult to interpret for non-financial sectors (like gambling) and risk leading to speculative assessments of potential harm rather than measurable impact.
BOS, through its Secretary-General Gustaf Hoffstedt, also raised concerns about the use of total annual turnover as a metric for determining the financial strength of an operator when calculating penalties.
According to Hoffstedt’s answers, turnover figures in gambling typically represent the total value of bets placed by customers rather than an operator’s actual revenue and therefore are not a good metric to use.
Instead, the group recommended that regulators consider gross gaming revenue (GGR) as a more accurate measure of financial capacity, warning that reliance on turnover could significantly overstate an operator’s ability to pay fines.
The consultation submission also called for clearer definitions within the draft standards, including more precise timelines for regulatory responses and remediation efforts and stronger coordination between AML supervisors and national gambling regulators before imposing sanctions that could affect licensing status.
The Anti-Money Laundering Authority was established in 2024 to combat financial crime but took responsibility for direct supervision of high-risk financial institutions as of 1 January 2026
