A Swedish administrative court has upheld enforcement actions taken against three gambling operators after determining that they committed serious breaches of anti-money laundering regulations through inadequate customer due diligence procedures.
The ruling supports decisions previously issued by Sweden’s gambling regulator, Spelinspektionen, against Betsson Nordic Ltd, Snabbare Ltd and Spooniker Ltd. Following a review of the cases, the court agreed with the regulator’s assessment that the companies failed to meet required standards for customer knowledge and monitoring under the country’s anti-money laundering framework.
Spelinspektionen announced that the court found sufficient grounds for the warnings and penalty fees imposed on the operators. The sanctions were originally issued in May 2025 after the regulator investigated how the companies handled customer due diligence obligations.
According to the regulator, the companies were responsible for “serious violations of the money laundering regulations through insufficient customer due diligence measures.”
Court Backs Regulator’s Findings
The cases stemmed from a review conducted by Spelinspektionen involving customers between the ages of 18 and 29. The regulator examined a list of the 50 individuals within that age group who made the largest cumulative deposits during the period from 1 January to 31 December 2023.
During its investigation, the regulator concluded that the operators had not sufficiently established the source of funds behind substantial customer deposits when those amounts appeared inconsistent with the players’ reported taxable income.
As part of the review, the regulator identified examples where customers deposited sums that exceeded what could reasonably be explained by their declared earnings. The authority determined that the operators had not taken adequate steps to verify the origin of those funds before allowing continued gambling activity.
The court ultimately agreed with that assessment and confirmed that the deficiencies were serious enough to justify regulatory intervention.
Betsson received a warning and a penalty fee of SEK 6.5 million. Snabbare was ordered to pay SEK 5.5 million, while Spooniker received the largest sanction of the three at SEK 10 million.
Customer Deposit Review at Center of Case
One of the examples highlighted during the investigation involved a Betsson customer who made 163 deposits between 19 September and 30 December 2023. The deposits totaled SEK 491,950 despite the individual reporting an annual net income of SEK 310,000. According to the regulator’s findings, the customer’s risk classification remained between low and medium throughout the period.
Spelinspektionen argued that the operator failed to adequately investigate the source of funds supporting that level of gambling activity.
The companies maintained that the high deposit levels could be explained by previous gambling winnings. However, the regulator challenged that explanation, arguing that the origin of the funds had not been properly verified through customer due diligence procedures.
The court agreed that the operators had not sufficiently demonstrated the legitimacy of the deposits and therefore upheld the sanctions.
Operators Continue to Challenge Interpretation
Despite the court’s ruling, the affected operators have continued to dispute the regulator’s interpretation of anti-money laundering requirements.
Betsson argued that the regulator had adopted an overly restrictive approach regarding how operators should verify funds linked to previous gambling withdrawals.
“The interpretation of the Swedish Gambling Authority – that licensees may only take into account previous withdrawals if they have verified that they are indeed from there as later deposits by continuously obtaining account statements – is incorrect,” Betsson stated.
“It goes against the previous practice of the administrative court, the preparatory work of the money laundering regulations and supranational guidance. Furthermore, it lacks a connection to both the risk-based approach and the facts of the case. The interpretation is also disproportionate and violates the principles of equal treatment.
“The decision violates the principle of equal treatment, since the administrative court previously has overturned decisions regarding comparable but more serious circumstances, where the operator in question had failed to obtain income information, significantly higher net deposits than Betsson without customer due diligence measures and in several cases disregarded its documentation obligation.
The decision also violates the principle of legality in that the company had no reason to expect the Swedish Gambling Authority’s interpretation of the requirement on how customer due diligence measures should be implemented.
In any case, Betsson’s possible violations have neither been systematic nor serious. If the Administrative Court finds that there are grounds for an intervention, the sanction fee should therefore be reduced completely or at least reduced significantly.”
Snabbare, which is owned by ComeOn Group, also disagreed with the regulator’s conclusions and reportedly described Spelinspektionen’s position as “wrong for several reasons”.
Spooniker, formerly a subsidiary of FDJ United and no longer active in the Swedish market, similarly criticized the regulator’s approach. The company argued that Spelinspektionen’s decisions are “consistently imprecise”.
Enforcement Action Comes Amid Wider Industry Challenges
The court’s decision arrives at a time when licensed gambling operators in Sweden continue to raise concerns about competition from unlicensed gambling providers.
Industry estimates cited alongside the ruling suggest that Sweden’s black market gambling sector generates between SEK 3.6 billion and SEK 7.3 billion in revenue, with gross turnover estimated at between SEK 60 billion and SEK 120 billion.
While the debate over channelization and unlicensed gambling remains ongoing, the latest court ruling reinforces Spelinspektionen’s authority to take enforcement action against licensed operators that fail to meet anti-money laundering obligations. By supporting the regulator’s findings against Betsson, Snabbare and Spooniker, the Administrative Court has confirmed that shortcomings in customer due diligence can warrant both formal warnings and significant financial penalties under Sweden’s regulatory framework.