BOS Report Claims Spelinspektionen AML Fines Run Close to Legal Maximum

Swedish online gambling trade body BOS published a Nordic Legal comparison on 27 October 2026 claiming that Spelinspektionen AML fines sit close to the legal maximum more often than penalties imposed by other Swedish authorities.

The report, "Tillsyn i fokus / Under Scrutiny", was commissioned by Branschföreningen för Onlinespel (BOS), the Swedish online gambling industry association, and written by Maria McDonald of Nordic Legal. It is an industry-commissioned comparative study, not a regulatory decision, and it describes itself as a basis for discussion. Its subject is Spelinspektionen, the Swedish Gambling Authority.

What the report compares

The study sets Spelinspektionen's supervision and sanction decisions against three other Swedish bodies: Finansinspektionen (FI), the financial supervisor; Länsstyrelsen i Stockholms län, a county administrative board with AML supervisory duties; and Skolinspektionen, the schools inspectorate. It looks at three areas: AML supervision, suitability checks on owners and management, and the size of sanction fees.

BOS summarizes the result as a more formalistic method and harsher sanctions at Spelinspektionen. The report itself is narrower. It says Spelinspektionen does not issue harsher sanctions in absolute terms, and that its findings do not show the regulator is always stricter. Conclusions are limited to the reviewed material and to AML supervision. The authorities also have different mandates and legal frameworks, and the study relies on selected cases.

AML sampling and fines near the cap

In 11 of the 12 Spelinspektionen AML decisions reviewed since 2021, supervision rested mainly on a limited sample of 5-15 customer files. The operator's general risk assessment and overall procedures were expressly outside the review. The report calls this method "more formalistic" but says nothing it reviewed makes it legally impermissible.

On fines, the report examined nine published AML decisions from 2022 to 2025. Seven were at 50% or more of the legal maximum, and two were at about 91% and 100%. Six of the seven are named in the report's table:

The 2021 decisions against LeoVegas and Mr Green were at 15-20% of the maximum, which the report reads as a drift toward higher fines over time. The comparators look different. FI's large bank fines run at 20-27% of its ceiling, with Klarna's SEK 500m penalty at about 20%. Länsstyrelsen Stockholm is typically lower still, with Louis Vuitton at 45% and Bolagsrätt Sundsvall at 14%.

Old cap, new rule

The near-maximum findings relate to the earlier penalty ceiling. Until 1 June 2024, AML fines were capped under chapter 7, section 14 of the Money Laundering Act (PTL) at EUR 1m or twice the profit gained. A change (SFS 2024:255) introduced chapter 18, section 21a of the Gambling Act, setting a fee of at least SEK 5,000 and at most the highest of 10% of turnover, twice the profit, or EUR 1m.

The new rule applies only to breaches committed after 1 April 2024. The report says it had not yet been applied in any Spelinspektionen decision. How fines are measured against the higher ceiling is therefore untested. BOS has also pressed this theme in its reaction to the EU AML package; see the earlier report on BOS and the EU AML fine plan.

Suitability checks and late reporting

Since the Gambling Act took effect, Spelinspektionen has issued decisions against 36 operators over owner and management suitability, all in 2025 or 2026. The outcomes were:

Every intervention concerned late reporting of ownership or management changes, and in every case the new individuals were judged suitable. One example is a set of Brunflo sports clubs that received a warning and a SEK 68,000 fee on 9 April 2026, which the report puts at 60% of the maximum. It found no comparable late-reporting sanctions at FI or Skolinspektionen. Licensing activity continues apace, as seen when S Gaming secured a Swedish license.

Appeals and the wider debate

Annex 1 shows that courts have trimmed some penalties:

• ATG's SEK 6m fine was cut to SEK 3m by the Court of Appeal.
• Videoslots' SEK 9m fine was cut to SEK 4m by the Administrative Court; the appeal is pending in the Court of Appeal.
• The Spooniker II fine was upheld and the judgment is final.
• LeoVegas' 2021 decision was appealed, and the appeal was withdrawn.

BOS Secretary General Gustaf Hoffstedt said in the press release that the licensed market would benefit if the regulator worked more like other authorities, with more risk-based supervision to the benefit of AML work and other oversight. BOS's recommendations have no legal effect.

The report arrives against earlier criticism pointing the other way. The Swedish National Audit Office (Riksrevisionen) concluded in report 2024:19 that Spelinspektionen's supervision was not effective enough, citing few inspections, weak risk analysis and weak follow-up of corrections. That review was previewed in coverage of the audit office's launch of its inquiry. The regulator has also expanded its toolkit, as described in its enhanced supervision of operators. BOS has long argued for a review of the framework, as in its support for the Gambling Act review.

For operators, the practical takeaways are limited but concrete: customer-file sampling remains the core of Swedish AML inspections, late ownership and management notifications draw sanctions even when the individuals are suitable, and fines imposed under the older cap have been reduced on appeal in some cases.

Status reviewed on 2 November 2026. Figures come from the BOS press release and the Nordic Legal report, both dated 27 October 2026. More regulation news and EMEA coverage.