Spelinspektionen questions Sweden’s new EU anti-money laundering proposals

Sweden's gambling regulator, Spelinspektionen, has raised several legal and supervisory concerns about proposed changes to Swedish legislation implementing the European Union's anti-money laundering framework. In a consultation response published on 27 October 2026, the authority broadly supported the Swedish government's legislative proposals but identified provisions it believes require reconsideration or greater clarity.

The response concerns a memorandum prepared by the Swedish Ministry of Finance to align national legislation with the EU's anti-money laundering package. Although Spelinspektionen supports much of the proposed framework, its objections focus on the planned allocation of responsibilities for registered lotteries and the enforcement powers available to supervisory authorities.

The submission highlights a practical question for Swedish lawmakers: how can the country implement wider European financial crime prevention standards while ensuring that regulatory responsibilities remain clear and supervisory authorities retain effective tools to carry out their duties?

Spelinspektionen identifies concerns over registered lotteries

One of the regulator's principal objections concerns a proposal under which Spelinspektionen would assess suitability and supervise registered lotteries. The authority supports the memorandum in general but does not agree with this particular allocation of responsibilities.

Its position is set out in the following statement: “largely agrees with the memorandum's proposal. However, the Swedish Gambling Authority opposes the proposal that the authority should test suitability and supervise registered lotteries.”

The distinction matters because registered lotteries operate under a different administrative arrangement from other forms of licensed gambling. Under Sweden's existing framework, municipalities have a role in registering and supervising qualifying local lotteries. Any change to the Swedish Gambling Authority's responsibilities would therefore need to establish clearly how regulatory duties should be divided between national and local bodies.

The consultation response should not be interpreted as a general rejection of lottery regulation. Instead, the objection concerns the specific proposal to assign additional suitability assessments and supervisory responsibilities to the national gambling authority.

Clear legislative drafting will be important if the government intends to change the existing arrangement. Operators, local authorities and regulators need to understand which body is responsible for compliance assessments, inspections and any subsequent enforcement action.

Enforcement powers remain another point of disagreement

Spelinspektionen has also challenged the memorandum's approach to the enforcement tools available to supervisory authorities. Its concern relates to whether an authority should be able to combine a formal request for information and documentation with a penalty payment designed to encourage compliance.

In its consultation response, the regulator states: “The Swedish Gambling Authority does not share the memorandum's assessment that the supervisory authorities should not be able to combine an order to provide the information and documents necessary for supervision with a fine. In addition, the Swedish Gambling Authority considers that certain provisions are unclear.”

The issue is important because effective supervision often depends on regulated organisations providing information within specified timeframes. If an authority cannot attach an appropriate enforcement mechanism to an information order, obtaining the material needed to assess compliance may become more difficult.

The Swedish legal terminology surrounding this issue also requires care. A vite is generally understood as a conditional penalty payment linked to compliance with an order. It is not necessarily the same as an administrative sanction imposed for a completed regulatory breach. The distinction may be important when interpreting the final wording of any legislation.

Spelinspektionen's response indicates that it wants the proposed rules to preserve effective supervision while providing legal clarity. Its concerns do not, by themselves, establish that the government's proposal is unlawful or that the final legislation will retain the disputed provisions.

A separate lottery decision provides useful context

The debate over registered lotteries comes alongside a separate enforcement decision concerning physical lottery tickets. In October 2026, Spelinspektionen announced a warning and a SEK 150,000 sanction fee against a lottery operator over deficiencies in the information provided on physical tickets.

That decision concerned compliance with requirements governing lottery-ticket information and related technical rules. It should not be treated as proof that the authority currently supervises every category of registered lottery or as a direct resolution of the separate legislative question raised in the consultation response.

The distinction is significant for an accurate understanding of the regulator's position. Different gambling arrangements can fall under different licensing, registration and oversight requirements. A decision involving one category does not necessarily determine which authority should supervise another.

The wider issue is whether the proposed legislation will produce a clear and workable division of responsibilities. The final framework will need to address how the requirements apply in practice without creating uncertainty for local authorities, lottery organisers or the national regulator.

Bet365-related penalties remain in place

The consultation response also arrives amid continued regulatory activity in Sweden's gambling market. On 14 October 2026, Spelinspektionen reported that the Administrative Court of Appeal had rejected appeals by two licensed businesses associated with bet365‘s Swedish gambling operations.

The court upheld warnings and sanction fees of SEK 4 million and SEK 40 million respectively. The cases concerned findings of serious breaches involving the statutory duty of care and deposit-limit requirements. The combined financial penalties total SEK 44 million.

These proceedings are separate from the EU anti-money laundering consultation. They nevertheless illustrate the broader regulatory context in which Swedish gambling operators must comply with requirements covering consumer protection, responsible gambling and other statutory obligations.

The cases also demonstrate why the legal basis for supervisory intervention and the scope of enforcement powers matter to both regulators and regulated businesses. Any assessment of future AML legislation should remain distinct from the findings in these separate gambling-law proceedings.

Peter Knutsson begins his term as director general

Another relevant development is the leadership change at Spelinspektionen. Peter Knutsson took office as director general on 17 August 2026 following his appointment by the Swedish government in March. His six-year term is scheduled to run until 31 August 2032.

Knutsson's professional background includes legal work, consumer protection and previous service at the Ministry of Finance. He also served as Sweden's advertising ombudsman before taking up the regulatory position.

A separate AML-related change took effect on 1 September 2026, when land-based commercial casino gambling became subject to Sweden's anti-money laundering framework without the previous exemption. The regulatory change followed an updated risk assessment that no longer considered the money-laundering risk associated with this category of gambling to be low.

The change was part of the authority's regulatory work and should not be presented as a policy decision personally initiated by Knutsson. It nevertheless forms part of the wider environment in which the regulator is assessing risks, supervising operators and adapting national gambling rules.

What happens next with Sweden's AML proposals?

The memorandum forms part of Sweden's effort to adapt its legislation to the EU's broader anti-money laundering framework. The European rules are intended to strengthen common standards for preventing money laundering and terrorist financing, while the Swedish proposals address how those obligations should be implemented through national legislation and supervisory arrangements.

The government has proposed that most of the Swedish legislative changes take effect on 10 July 2027. The consultation process remains important because responses from affected authorities and other stakeholders can identify practical difficulties before the proposals advance further through the legislative process.

Spelinspektionen's submission does not mean that the disputed provisions have been withdrawn. Its objections instead identify questions for lawmakers to consider when reviewing the memorandum and preparing any subsequent legislation.

Particular attention is likely to be needed on the precise responsibilities of national and local authorities, the scope of suitability assessments and the enforcement mechanisms available when information is required for supervision. The final provisions will need to balance consistent legal standards with an administrative structure that can function effectively.

Conclusion

Spelinspektionen's response to Sweden's EU anti-money laundering proposals highlights the importance of clear legal responsibilities in a regulated gambling market. Although the authority broadly supports the government's direction, its objections show that agreement on policy objectives does not automatically translate into agreement on how those objectives should be implemented.

The questions concerning registered lotteries and supervisory enforcement powers deserve careful consideration because unclear rules can complicate both compliance and enforcement. A well-defined framework should identify the responsibilities of each authority, explain how information requests can be enforced and ensure that regulated organisations can understand their legal obligations.

The separate developments involving lottery-ticket requirements, gambling-law penalties and the extension of AML rules to land-based commercial casinos illustrate the range of issues facing Swedish gambling oversight. They should remain legally distinct, even as they contribute to the wider regulatory picture.

Ultimately, the consultation process provides an opportunity to refine the proposed legislation before the new requirements take effect. The outcome will matter not only for Spelinspektionen but also for local authorities and gambling operators that need predictable rules. A carefully drafted legal framework could support more consistent supervision while preserving the safeguards necessary to address financial crime and protect consumers.

FAQs

What is Spelinspektionen?
Spelinspektionen is Sweden's national gambling authority. It oversees gambling activities within its statutory remit and works to ensure that the Swedish gambling market operates lawfully and reliably.

Why has Spelinspektionen submitted a consultation response?
The authority submitted its response to comment on a Swedish Ministry of Finance memorandum containing proposals to adapt national law to the EU's anti-money laundering package.

Does Spelinspektionen oppose the entire EU anti-money laundering package?
No. The authority broadly supports the memorandum's proposals but has raised specific objections concerning registered lotteries, supervisory enforcement powers and unclear legal provisions.

What is the main concern regarding registered lotteries?
Spelinspektionen opposes the proposal that it should assess suitability and supervise registered lotteries. The issue concerns the allocation of responsibilities rather than a general objection to regulating lotteries.

Why are supervisory enforcement powers important?
Supervisory authorities may need information and documents to assess whether regulated organisations comply with legal requirements. The ability to attach an appropriate enforcement mechanism to an information order can help secure cooperation.

What is a conditional penalty payment under Swedish law?
A conditional penalty payment, commonly referred to as vite, is linked to compliance with an order. Its legal function differs from a conventional administrative fine imposed for a regulatory breach.

When did Sweden extend AML requirements to land-based commercial casinos?
The relevant change took effect on 1 September 2026, removing the previous exemption for land-based commercial casino gambling.

Who is Peter Knutsson?
Peter Knutsson is the director general of Spelinspektionen. He took office on 17 August 2026 and has a term scheduled to end on 31 August 2032.

What happened in the bet365-related court cases?
In October 2026, the Administrative Court of Appeal rejected appeals by two licensed businesses associated with bet365's Swedish gambling operations. Warnings and combined sanction fees of SEK 44 million remained in place in cases involving duty-of-care and deposit-limit requirements.

When are the proposed Swedish AML legislative changes expected to take effect?
The Swedish government has proposed that most of the changes take effect on 10 July 2027. The final implementation will depend on the legislative process.