Financial Crime World

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Anti-Money Laundering Guidelines in the Swedish Gambling Industry

The Swedish Gambling Authority’s guidelines for anti-money laundering (AML) provide a comprehensive framework for license holders in the gambling industry to comply with the Money Laundering Act. These guidelines outline key points to ensure effective prevention of money laundering and terrorist financing.

Customer Due Diligence

License holders must perform customer due diligence, which includes:

  • Verifying Customer Identity: Obtaining information on the customer’s identity and checking their source of funds.
  • Checking Source of Funds: This involves obtaining information on the origin of the customer’s financial resources.

Indications of High Risk

Customers who exhibit the following behaviors may be considered high-risk:

  • High Deposit Limits: Depositing more than EUR 2,000 or setting high deposit limits (over EUR 2,000) in a rolling 12-month period.
  • Excessive Gambling Activity: Engaging in gambling activities that exceed EUR 2,000 in a rolling 12-month period.

In such cases, license holders must take additional measures to address the risk of money laundering.

Indications of Normal Risk

Customers who exhibit the following behaviors may be considered normal-risk:

  • Low Deposit Limits: Depositing less than EUR 2,000 over a rolling 12-month period.
  • Reasonable Gambling Activity: Engaging in gambling activities that do not exceed EUR 2,000 in a rolling 12-month period.

However, if a customer sets remarkably high deposit limits, the license holder must remain vigilant and monitor their activities closely.

Monitoring

License holders must continuously monitor business relationships with customers to detect deviations from expectations. This includes:

  • Checking Transactions: Verifying transactions against customer due diligence, business, and risk profiles.
  • Monitoring Business Relationships: Keeping track of business relationships to identify potential money laundering or terrorist financing activities.

Reporting to Financial Police

Under the Money Laundering Act, license holders are obligated to report suspicious transactions to the Financial Police. No evidence of money laundering or terrorist financing is necessary for reporting.

Internal Control and Whistleblowing

License holders must establish robust internal control mechanisms, including:

  • Designated Officer: Appoint a specially designated officer responsible for AML compliance.
  • Central Function Manager: Establish a central function manager to oversee AML activities.
  • Independent Audit Function: Appoint an independent audit function where justified by size and nature of operations.
  • Whistleblower System: Implement a whistleblower system that allows employees and contractors to report breaches of anti-money laundering rules anonymously.

Overall, these guidelines provide a robust framework for license holders to prevent money laundering and terrorist financing in the gambling industry.