mOn 4th February 2025, the Swedish Gambling Authority (SGA) published its latest guidance on the Prevention of Money Laundering (ML) and Terrorist Financing (FT). This update provides crucial clarifications that were previously expected but not explicitly detailed in the SGA’s regulations and guidance documents. This article aims to highlight the specific clarifications from the February 2025 update. It will not be covering the Swedish gambling regulations in their entirety.
The SGA’s latest guidance is drawing on the experience gained from various investigations carried out on subject persons throughout the previous year. The primary shortcomings identified were related to the licensees’ work on customer due diligence (CDD), which was deemed to be insufficient, and this latest guidance aims to address the afore-mentioned shortcomings.
The key highlights of the SGA’s latest guidance are summarised below:
- Purpose and Nature of Business Relationship: The SGA has clarified that, regardless of the risk level, licensees must obtain information about the purpose and intended nature of the business relationship at onboarding. This information must be evaluated on an ongoing basis. This differs from the Malta Gaming Authority (MGA) requirement, which mandates that this information is collected at the €2,000 transaction threshold.
- Defining Entertainment Purpose: Licensees must define the concept of “entertainment purpose” to effectively identify deviant customer behaviour. According to Statistics Sweden, households spent 9.2% of their total expenditure on recreation, sports, and culture in 2023. This measure of entertainment consumption can provide guidance as to when the customer’s risk classification should be revised.
- Financial Thresholds: While most subject persons already have financial thresholds in place, the SGA now makes it clear that it requires these thresholds to be proportionate and based on an analysis of statistical data.
- Normal Risk Classification: The SGA has reiterated explicit criteria for when a customer is considered “Normal” risk. Customers who specify higher deposit limits than SEK 20,000 and/or play more than SEK 20,000 over a rolling 12-month period are considered normal risk. CDD measures for normal risk customers should include obtaining information about annual income, which is publicly available from the Swedish tax authority.
- Ongoing Monitoring: The SGA emphasizes that large, unusual, and/or irrational deposits should be stopped and verified before the customer can wager the deposit. These measures must be taken immediately, not only when the player wants to withdraw money from the gaming account.
In conclusion, the SGA’s February 2025 update provides much-needed clarity on several aspects of ML/FT prevention. By adhering to these guidelines, licensees can ensure robust compliance and reduce the risk of regulatory breaches. At ARQ, we are committed to helping you navigate these updates and implement effective compliance measures. Should you require a deeper understanding of the Swedish gambling regulations or assistance with any specific requirements in this respect, our team is here to support you.
How Can ARQ Group Help
At ARQ Group, we understand the complexities and challenges that come with adhering to the latest regulatory updates from the Swedish Gambling Authority. Our team of experts is dedicated to providing comprehensive support to ensure your business remains compliant and operates smoothly. Here’s how we can assist you:
- Regulatory Guidance: We offer detailed insights and interpretations of the SGA’s regulations, helping you understand and implement the necessary measures effectively.
- Compliance Audits: Our team conducts thorough audits to identify any gaps in your current compliance framework and provides actionable recommendations to address them.
- Training Programmes: We provide tailored training sessions through our learning platform at ARQEducate. Our tutors are subject-matter experts well-versed in the latest ML and FT prevention guidelines and will share best practices.
- Customer Due Diligence (CDD) Support: We assist in developing robust CDD processes that align with the SGA’s requirements, ensuring that you collect and evaluate the necessary information about your customers.
- Risk Management: Our experts help you establish proportionate financial thresholds and effective risk classification systems to monitor and manage customer activities.
- Ongoing Monitoring Solutions: We offer advanced monitoring strategies to detect and address unusual or suspicious transactions promptly.
By partnering with ARQ Group, you can navigate the regulatory landscape with confidence and focus on growing your business. Should you require a deeper understanding of the Swedish gambling regulations or assistance with any specific requirements, our team is here to support you every step of the way.
For more information, please contact Manfred Galdes on info@arqgroup.com
Manfred Galdes
Managing Partner
A lawyer by profession, Manfred Galdes is the managing partner at ARQ. He has spent over twenty years of experience practising in the area of regulatory and AML compliance, having held leading roles both in the private and public sector. A lawyer by profession, Manfred Galdes is the managing partner at ARQ. He has spent over twenty years of experience practising in the area of regulatory and AML compliance, having held leading roles both in the private and public sector.
