Money Laundering Casinos

The Swedish Gambling Authority (Spelinspektionen) updates its 2025 risk assessment on money laundering. The update is a practical tool to identify which game types are most vulnerable, the prevailing threats, and what operators must do to comply with anti-money laundering legislation.

What is new in the 2025 risk assessment on money laundering through gambling?

In its 2025 report, the Swedish Gambling Authority has introduced a new assessment methodology aligned with the EU’s supranational risk assessments and the Swedish national equivalent. This approach assesses risk in two stages: first, a separate analysis of threats and vulnerabilities; second, an overall risk level using a weighted risk matrix in which vulnerabilities carry greater weight than threats.

The report aims to:

• Provide an overview of threats, vulnerabilities and risks in the Swedish gambling market.
• Support supervision and assessments under the Anti-Money Laundering Act.
• Guide operators in designing measures to manage risk.

The update is also prompted by developments in the gambling market, including the winding-down of Casino Cosmopol in Stockholm from 1 January 2026.

Money laundering through gambling: highest-risk game types

The greatest risk arises in commercial online gambling and online betting. This is mainly because these game types offer:

• High stakes and winnings: Enable the turnover of large sums.
• High availability: Gambling occurs around the clock via digital platforms.
• Use of gambling accounts: Risk that accounts are used to store, transfer or cycle criminal proceeds.

In the risk overview, these game types are assessed to have a high inherent risk, while state-owned casinos and land-based betting present significant risk. Lotteries with gambling accounts and land-based commercial casino games are classified as medium risk.

Illustrative threats and vulnerabilities in gambling operations

The Swedish Gambling Authority highlights several concrete methods observed in practice:

• Consumption and cycling of criminal proceeds: Gambling is used to disguise the illicit origin of funds.
• Account-holding and storage: Criminal proceeds can be placed in gambling accounts and later withdrawn as seemingly legitimate winnings.
• Transfers via chip dumping: Particularly relevant in online poker where players/accounts act in concert.
• Gambling companies as crime enablers: Risk that companies are exploited or owned by criminal networks.

Several factors increase vulnerability in certain game types:

• High payout ratios: Make it possible to “clean” funds at low cost, sometimes cheaper than professional launderers.
• Cross-border transactions: Challenges with customer due diligence outside Sweden.
• Anonymity and lack of in-person interaction: Enable misuse of identities and weak controls.

What operators need to do now about money laundering through gambling

The Swedish Gambling Authority’s assessment serves as guidance for licensees and can be used to:

• Adjust internal risk assessments based on the inherent risk of the game types offered.
• Prioritise resources for customer due diligence and transaction monitoring towards high- and medium-risk gambling, applying a risk based customer due diligence approach.
• Implement preventive measures where, for example, gambling accounts or international payment solutions are used.

The risk levels in the report do not take into account each operator’s own risk controls. These must therefore be analysed and strengthened where necessary so that residual risk remains at an acceptable, controllable level.

How we can help – anti money laundering consulting services

At Morling Consulting, we are specialists in AML and money laundering through gambling and provide practical advisory support to ensure your operations meet the requirements of the Anti-Money Laundering Act and the Swedish Gambling Authority’s guidance. We deliver anti money laundering consulting services to operators across Europe. Contact us for an initial discussion on how we can support your business.