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Swedish Court Upholds SEK22M AML Fines Against Three Operators

Swedish Court Upholds SEK22 Million in AML Fines Against Betsson, Snabbare and Spooniker – Rulings Clarify Source of Funds Requirements for Gambling Operators

Key Takeaways

• The Administrative Court in Linköping upheld SEK22 million in anti-money laundering fines against Betsson Nordic, Snabbare and Spooniker.
• The court rejected the operators’ argument that new deposits could be treated as low risk if customers had previously withdrawn gambling winnings.
• Betsson was fined SEK6.5 million, Snabbare SEK5.5 million and Spooniker SEK10 million.
• The judges ruled that recycled winnings and closed-loop payments do not replace enhanced customer due diligence when deposit levels indicate higher risk.
• All three decisions can be appealed to the Administrative Court of Appeal in Jönköping.

Court Rejects Appeals and Confirms Regulator Sanctions

On July 2, the Administrative Court in Linköping rejected appeals filed by Betsson Nordic, Snabbare and Spooniker against anti-money laundering penalties issued by Sweden’s gambling regulator, Spelinspektionen. The regulator announced the rulings the following day.

The combined fines amount to SEK22 million. Betsson must pay SEK6.5 million, Snabbare SEK5.5 million and Spooniker SEK10 million. In addition to the financial penalties, previously issued warnings remain in place.

Although the court dismissed all three appeals and upheld the sanctions, it did not fully endorse every aspect of the regulator’s reasoning in two of the cases. Nevertheless, the fines and warnings were left unchanged.

Central Dispute Focused on Source of Funds Checks

All three cases revolved around a single anti-money laundering issue. The operators had assessed certain customer deposits as low risk because the same customers had previously withdrawn gambling winnings, often through the same bank account.

The companies argued that these prior withdrawals justified treating subsequent deposits as less risky, on the assumption that the funds originated from earlier winnings.

The court rejected this approach. It ruled that assuming new deposits stem from previous gambling profits does not meet the requirements for enhanced customer due diligence. According to the judgment, operators must obtain sufficient information to verify the source of funds and properly assess money laundering risk when customer activity reaches higher levels.

The rulings clarify that closed-loop payment patterns, previous withdrawals or so-called recycled winnings cannot substitute for reliable financial documentation, such as bank statements, when deposit volumes create increased risk.

Betsson and Snabbare: Serious but Not Systematic Breaches

Betsson’s case involved eight customers between the ages of 20 and 29. Over several months, these individuals deposited amounts ranging from SEK133,584 to SEK491,950.

The court acknowledged that reviewing a relatively small number of customers did not demonstrate a systematic failure across the entire business. However, it still classified the identified shortcomings as serious breaches of anti-money laundering obligations. The SEK6.5 million fine and warning were therefore upheld.

Snabbare’s case concerned 10 customers who deposited significantly larger sums, ranging from approximately SEK950,000 to SEK3.2 million. The operator pointed to manual reviews and the filing of a report with Finanspolisen, Sweden’s financial intelligence unit.

The court found that these steps did not demonstrate that monitoring had occurred early enough to meet regulatory standards. As in Betsson’s case, the judges granted a narrow concession by acknowledging that the sample did not prove systematic failings. Nevertheless, they considered the violations serious and confirmed the SEK5.5 million penalty.

Spooniker: Repeated Failures Lead to Higher Fine

Spooniker’s case involved five customers. Unlike the other two operators, Spooniker did not receive similar relief from the court.

A key factor was a previous anti-money laundering warning issued in 2022 for comparable weaknesses in enhanced due diligence and customer risk controls. The court viewed the later breaches as repeated failings rather than isolated incidents.

As a result, Spooniker received the highest fine of the three companies, amounting to SEK10 million. The court maintained both the financial penalty and the warning.

Compliance Implications for Licensed Swedish Operators

The decisions provide direct guidance for licensed gambling operators in Sweden. The court made clear that customer behavior suggesting higher risk, particularly large or repeated deposits, requires enhanced due diligence measures.

Operators cannot rely solely on internal transaction histories or assumptions that funds originate from previous gambling activity. Instead, they must gather sufficient and reliable information to verify the source of funds and assess money laundering risk in a timely manner.

For users, the rulings indicate that operators may request additional financial documentation when deposit levels increase or when patterns trigger enhanced scrutiny. Such checks are part of the regulatory framework that governs licensed gambling services in Sweden.

All three companies retain the option to appeal the decisions to the Administrative Court of Appeal in Jönköping.

Our Assessment

The Administrative Court in Linköping has upheld SEK22 million in anti-money laundering fines against Betsson Nordic, Snabbare and Spooniker, confirming that prior withdrawals and recycled winnings do not replace enhanced source of funds verification. While Betsson and Snabbare were found to have committed serious but not systematic breaches, Spooniker’s repeated shortcomings following a 2022 warning resulted in the highest penalty. The rulings set a clear compliance benchmark for Swedish licensed operators regarding customer due diligence and money laundering risk assessment.