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Anti-Money Laundering Regulations in Sweden: Guidance for License Holders

This document provides guidance on the anti-money laundering (AML) regulations in Sweden, specifically for license holders in the gambling industry.

Customer Due Diligence

Key Requirements

  • Perform customer due diligence (CDD) to identify and verify customers.
  • Obtain identification documents, verify the customer’s identity, and assess the risk associated with the customer.

CDD Process

  • Obtain identification documents from customers
  • Verify the customer’s identity
  • Assess the risk associated with the customer

Risk Classification

High-Risk Customers

  • Customers who set higher deposit limits than EUR 2,000 or gamble more than EUR 2,000 in a rolling 12-month period are considered high-risk.
  • If there is an indication that a customer should be classified as high-risk, license holders must take additional measures to address the risk of money laundering.

Normal-Risk Customers

  • Customers who set higher deposit limits than EUR 2,000 and/or gamble more than EUR 2,000 in a rolling 12-month period but do not pose an increased risk of money laundering are considered normal-risk.
  • License holders must still perform ongoing monitoring to detect deviant transactions and activities.

Low-Risk Customers

  • Customers who make deposits totaling less than EUR 2,000 over a rolling 12-month period are considered low-risk.
  • However, if a customer sets remarkably high deposit limits, license holders must be vigilant that gambling does not escalate rapidly.

Ongoing Monitoring

  • License holders must continuously monitor the business relationship with customers to detect deviant transactions and activities.
  • The scope and frequency of monitoring depend on the risks in the current business relationship.

Deviant Transactions

  • Monitor for transactions that are unusual or suspicious
  • Take action if a transaction is identified as deviant

Reporting to the Financial Police

  • Under the Money Laundering Act, license holders are obliged to review and report suspicious transactions to the Financial Police.
  • No evidence that money laundering or terrorist financing has actually taken place is necessary.
  • It is prohibited under the Money Laundering Act to tell customers or third parties that a report has been made.

Reporting Process

  1. Review transactions for suspicious activity
  2. Report suspicious transactions to the Financial Police
  3. Keep records of reports and investigations

Internal Control and Whistleblowing

  • License holders must appoint a member of the management team, central function manager, and independent audit function where justified by the size and nature of operations.
  • A whistleblower system must be in place, allowing employees and contractors to report internally if the license holder breaches anti-money laundering rules.

Whistleblowing Process

  1. Employees and contractors can report suspicious activity
  2. Reports are reviewed and investigated by internal authorities
  3. Action is taken if a breach of AML rules is found

Overall, this guidance provides license holders with a comprehensive framework for implementing effective AML measures to prevent money laundering and terrorist financing in the Swedish gambling industry.