TSG, Betsson, and Snabbare Failed to Monitor User Deposits Adequately

TSG, a Flutter subsidiary, received the highest penalty of SEK 7 million ($730,117). Key findings of the regulator’s investigation include that the operator failed to apply enhanced due diligence measures properly for customers with unusually high deposits.

Spelinspektionen discovered that TSG had set internal threshold alerts of $20,000 for a single deposit and $40,000 in net deposits within a year to trigger an investigation into the source of the funds.

The regulator found the limits to be too high, allowing potentially risky activity to go undetected. It also criticized TSG’s documentation collection process.

Betsson received a fine of SEK 6.5 million ($677,966) for failing to implement proper due diligence measures and inadequate transaction monitoring. A Spelinspektionen investigation into 10 high-depositing customer accounts discovered that only two were compliant with regulations.

One customer was found to have made 163 deposits over a period of several months, totaling SEK 491,950. That customer had a net annual income of SEK 310,000. Still, the user was deemed to have a low to medium risk by Betsson’s system.

The regulator also fined Snabbare SEK 5.5 million ($573,663). Its investigation found that the operator accepted deposits that exceeded customers’ income.

Spelinspektionen determined that Snabbare’s customer knowledge is insufficient and that the operator’s delayed actions increased the risk of money laundering exploitation.

Spelinspektionen’s Continued AML Enforcement

The latest crackdown on Betsson, Snabbare, and TSG, highlight Spelinspektionen’s strict approach to monitoring AML protocols, including customer due diligence, transaction monitoring, and source-of-funds verification.

Just a month prior, the regulator fined Spooniker, a subsidiary of the Kindred Group, SEK 10 million ($1.1 million) for a failure in AML compliance. That included inadequate due diligence measures.

Similar AML shortcomings led to a SEK 12 million ($1.3 million) fine for Videoslots in April. Identical to the TSG case, an investigation of 12 user accounts found numerous breaches of the Swedish Gambling Act.

The April fine came less than six months after Spelinspektionen fined Videoslots SEK 4 million ($417,014) for similar AML failures. The fine was originally SEK 9 million, but the courts reduced it to SEK 4 million.

Other notable penalties for AML breaches include:

• Svenska Spel: SEK 100 million ($10.4 million) in 2024 (Svenska Spel won an appeal recently)
• TSG: SEK 7 million ($729,774) in 2023
• Betsson: SEK 5 million ($521,267) in 2022

Betsson Pulls Out of Holland Gaming Technology Acquisition

Other significant news for the Swedish-based Betsson Group is its announcement of the termination of the agreement to acquire Holland Gaming Technology and Holland Power Gaming in the Netherlands.

Betsson announced the deal in February 2024, pending approval by the Dutch Gambling Authority. The company stated that, since the regulator has not issued a decision by the agreed-upon long-stop date, it has decided to halt the acquisition process. Instead, Betsson will focus on other opportunities.

The agreed-upon purchase price was €27.5 million ($31.4 million). With the termination of the agreement, the sellers will return the sum to Betsson, minus a break fee of €800,000 ($911,900).

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The Jakarta Globe reported that the Financial Transaction Reports and Analysis Center (PPATK) says many accounts were used in bank account trading schemes.

Indonesia AML Agency: Criminals Target Dormant Accounts

Criminals used many of the accounts to deposit funds on illegal gambling platforms, the agency explained. The PPATK outlined that criminals used some of the accounts to launder the proceeds of fraud and narcotics sales.

Ivan Yustiavandana, the head of the PPATK, explained that many criminals are now targeting dormant bank accounts.

As such, the agency has temporarily suspended many such accounts, concerned that more criminals could hijack them. However, the same media outlet claimed that the freeze orders have seen several bank account holders come forward with complaints.

Yustiavandana claimed that bank customers whose accounts have been suspended can reactivate their accounts with relative ease.

However, the agency has warned that citizens should take proactive steps to safeguard their bank accounts from criminals and fraudsters linked to online gambling.

Protect Your Accounts, Agency Chief Warns

The PPATK told the public to take preventive measures, including closing unused bank accounts. The AML agency also advised citizens not to share personal data with unknown individuals.

It said Indonesians should “immediately report any suspicious transfers from unfamiliar sources to banks or law enforcement agencies.”

Indonesia’s crackdown on illegal gambling began under former President Joko Widodo. His successor, Prabowo Subianto, has since intensified the drive.

Jakarta says it has removed or blocked access to 900,000 gambling-related webpages and social media posts since Prabowo was inaugurated on October 20, 2024. The Indonesian police also recently made two arrests relating to the operation of the TAHU69 portal.

Earlier this month, the PPATK and Indonesian police announced they had frozen around $36.2 million of gambling-linked funds. At the time, Ivan said that officials had also temporarily suspended over 5,000 bank accounts.

Ivan claimed: “The core objective of this law enforcement initiative is to protect the public from the social harms of online gambling.” The agency chief warned that online betting “can also lead to the breakdown of families.”

However, some lawmakers in the country have urged Jakarta to consider legalizing casinos, following similar plans in the United Arab Emirates. The UAE is set to open its first casino in 2027.

The top Indonesian Islamic body has hit out at the proposal. An official told lawmakers to “not even think about legalizing gambling to increase state revenue.”

Another senior official explained that legalizing betting in Indonesia was “unthinkable,” explaining that gambling violates community norms.

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Companies holding a UK gambling license are required to keep up with emerging risk information published by the Commission. The release of updated guidance serves as a “trigger for operators to review their money laundering and terrorist financing risk assessments and related policies, procedures and controls.” 

The UKGC update from April 2025 highlights 13 broad AML risks:

1. Money service business activity in remote and non-remote casinos.
2. Artificial intelligence used to bypass customer due diligence.
3. Money in exchange for personal details and gambling accounts.
4. Third-party business relationships, including white-label partnerships and investments
5. Open-loop payment processes
6. Licensed software providers’ games on unlicensed websites
7. Cryptoassets
8. Terminals used to facilitate payments in non-remote casinos
9. Changing customer demographics in the non-remote casino sector
10. Adult gaming centre premises converting to licensed bingo premises
11. Crash games
12. Application Registration Cards
13. Jurisdictions subject to increased monitoring by FATF

Several of the above are regarding activities undertaken online and cover emerging trends in technology and consumer behavior. Several have specific applications to the emergence of crypto casinos and offshore gaming sites. 

UK Licensees Offering Games to Illegal Operators

The Commission has pointed to a rise in casino games that are developed by licensed software operators in the UK being available on unlicensed websites that are accessible and target the UK market. It outlines that those undertaking such activity are “at risk of accepting funds derived from criminal activity.” 

The Commission advises operators to “actively monitor their business relationships to ensure that partners are not offering illegal gambling facilities” to the British market. Should there be non-compliance, operators are required to terminate these relationships immediately. “Actively notifying the Commission and presenting a clear and prompt plan to mitigate the issue is a minimum requirement.” 

Growing Interest in Crypto Sparks UKGC AML Concern

Increasing interest in cryptocurrencies within the licensed gambling industry has been noted as an area of concern from a money laundering perspective. The UKGC officially rates crypto as a ‘high-risk payment method.” 

Guidelines also note a large theft of crypto from the ByBit exchange in February 2025. They claim that the group alleged to have undertaken the theft is ” suspected to use complex online money laundering systems, which, in the past, have been thought to include remote gambling operators around the world.” 

The UK regulator has urged vigilance with regard to the use and acceptance of crypto assets. As the number of payment providers that offer crypto payment facilities increases, operators are encouraged to have a “full understanding of the services provided” by their payment providers. 

Additionally, where source of funds checks show that customers’ funds to gamble have come from crypto trading, this should be considered as a high-risk indicator, and sufficient due diligence must be undertaken. 

Crash Games Bring AML Risks

Updated guidance notes that “Crash games have been offered by crypto casinos […] for a number of years.”

It continues: “We have been made aware of an increased interest in crash games within the legal, licensed casino sector, so we are drawing operators’ attention to the risks of this game type.” 

The mechanics of crash games, which allows customers to cash out at any point after an initial bet is made (as the multiplier grows), can allow criminals to “camouflage the high-risk behaviour of cashing out quickly with limited gameplay within the context of the crash game (where these behaviors are inherently more common), and that transactional monitoring controls may not be effective in detecting suspicious activity.” 

The UKGC advises operators to assess the AML risk of any new product they launch. It adds, “Operators must then ensure they have appropriate procedures in place to prevent money laundering.” It suggests using the feed of crash game activity to build into a customer’s overall risk profile. 

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Impressive and encouraging – two words that we do not hear often when referring to gambling operators and their approach to compliance but, nonetheless, two words that AMLGS feels best describe how the majority of operators have handled the huge challenge that was handed to them when COVID-19 impacted the UK.

Unfortunately, as so frequently witnessed by this industry, much of the hard work has been overshadowed by negative press and papers published by governing bodies that have minimal first-hand knowledge about gambling operations other than what they themselves have read.

“Since the COVID challenge
was laid out for operators,
they have risen to it“

Often this represents unfair criticism from those without the appropriate level of knowledge and expertise – but let’s focus on the positives.

Since the COVID challenge was laid out for operators, they have risen to it. To manage what could have been a huge increase in problem gambling and instead see almost no difference in the ‘post-pandemic’ period has been great to see – noting, of course, that we are not out of the woods yet.

Many of the operators we work with have put in strenuous effort to protect consumers and meet regulatory requirements. Our launch of the Responsible Gambling Risk Assessment (RGRA) happened to come just in time, enabling operators to quickly assess their customer base and dynamically apply appropriate measures.

With several of our partners subject to regulatory compliance assessments, the RGRA – along with their Compliance Health Checks – allowed these companies to evidence their policies and procedures to the high standard required.

For those of you that attended our webinar with the Malta Gaming Authority and global customer onboarding, identification and investigation provider HooYu or listened to our interviews with global partners Arctic Intelligence, you would likely have heard of our Responsible Gambling Risk Assessment and our Compliance Health Check mentioned.

The RGRA is essentially a mandatory licensing requirement for all operators in emerging markets (which we anticipate will become a requirement across all of the major markets in the near future).

Operators will be expected to provide an accurate assessment of the risk to their customers from problem gambling, accompanied by the appropriate level of mitigation. This is exactly what our RGRA offers and which a number of partners have already undertaken.

The Health-Check is a compliance MOT and, of course, it is better to have this done before something goes wrong. Operators should not wait to be put on notice of an audit/assessment – conducting an annual health check delivers assurances that no skeletons will come out of the closet during an assessment.

At AMLGS, we conduct mock interviews using templates designed alongside regulators’ own auditors to get businesses ready for the environment that they will likely experience. AMLGS reviews every aspect of compliance procedures.

Better us identify a problem than the regulator, something which has proven beneficial for every operator that has utilised this service.

We work with many of those reading this along with other operators across Europe and again, we want to congratulate you them, all their efforts. In a time when the sector is faced with seemingly non-stop bombardment of legislative changes and negative media coverage, we believe it is our job as your partners to highlight the good side of the business as well.

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At the heart of the changes is alleviating pressure on less developed regions, instead placing the focus on countries that exhibit higher threat levels when it comes to AML. 

The new changes could lead to as many as half of the currently listed countries being delisted as ‘low-capacity countries’ are filtered out.

As a result of the changes, countries will be assessed against three criteria in order to avoid being put on the greylist. 

Looking to focus on the most significant threats, only countries listed on the World Bank High-Income Countries list, or have financial sector assets above more than US$10bn measured by ‘broad money’, will be eligible for the list. 

Any country classified as a ‘least developed country’ under United Nations (UN) definitions will not be prioritised for an active FATF review, which is part of the process for when a country is placed on the greylist for being financially unsound.

Lesser developed countries could still be sanctioned in the event of the FATF agreeing that a significant money laundering, terrorist financing or proliferation of financing risks exists.

Nonetheless, if they do end up on the greylist they could be given a longer observation period than others. 

The new criteria will be applied during the next round of FATF assessments, and so could result in some countries being removed from the greylist or fewer countries being added to it. 

The FATF statement read: “The changes made by the FATF will ensure the listing process better targets the countries that pose the greatest risk to the international financial system and contributes to more adequate support to low-capacity countries.

“The impact of illicit financial flows is felt most strongly by the least developed countries as it impedes sustainable development,” the FATF explained.

“Proceeds of crimes, such as tax evasion, corruption and organised crime, divert billions of dollars annually away from essential public goods like education and health. 

“Depriving criminals from their ill-gotten gains is crucial to help these countries build robust economies and societies.”

The FATF greylist currently consists of Bulgaria, Burkina Faso, Cameroon, Croatia, the Democratic Republic of Congo, Haiti, Jamaica, Mali, Mozambique, Nigeria, Philippines, Senegal, South Africa, South Sudan, Syria, Tanzania, Türkiye, Vietnam and Yemen.

The GT AML and CTF initiative also maintains a separate ‘blacklist’ of high-risk jurisdictions, which currently only has three countries on its books – Iran, Myanmar and North Korea.

A look at the greylist shows that a significant percentage of listed countries are classed as developed according to UN standards. The FATF is concerned that these countries’ presence on the list could hold back economic development.

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The case is unfolding further after it was found that former Resorts World President Scott Sibella, who resigned last October, pleaded guilty to money laundering charges during his previous tenure at MGM Resorts.

Sibella allowed known illegal bookie Wayne Nix to gamble at the property despite him being aware of Nix’s money-making operation. 

The impact of that case continues to be felt however, and a myriad of other players could potentially be dragged in, with the Nevada Gaming Control Board now pursuing a disciplinary complaint against Resorts World Las Vegas and its parent and affiliated companies, as well as individuals working for the property. 

Central to the allegations from the NGCB are key violations of the Nevada Gaming Control Act and the Nevada Gaming Commission’s regulations, as it claimed that AML standards simply weren’t met by the operator. 

The NGCB has raised warnings that the environment at Resorts World had significant shortcomings in terms of its approach to compliance, becoming an entertainment destination with suspected or direct ties to illegal gambling businesses. 

There are accusations that the environment at Resorts World enabled bookie Matthew Bowyer to use funds he had obtained through illegal activity.  

Bowyer, who was charged with operating an illegal sports betting ring, agreed to plead guilty on 9 August to operating an unlawful gambling business, money laundering and subscribing to a false tax return for his role in the scheme.

Resorts World’s AML program underlines that it is essential for workers to report suspicious activity and any violations, but the NCGB alleges there was a complete disregard for regulations by the casino when it came to Bowyer and some associates.

There were several Resorts World executives, including Sibella, who had the unilateral authority to ban Bowyer but they allegedly turned a blind eye to his gambling.

The Bowyer case is one of a number of cases that Resorts World is in legal hot water over, with there also being a complaint filed by the NGCB that alleges Resorts World failed to bar, ban or restrict Edwin Ting, who ran an illegal gambling business. In 2014, Ting was sentenced to five months in prison in a New York federal court and ordered to forfeit $2m for running an illegal poker operation that used intimidation to collect debts from players who refused to pay.

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Reaching an agreement, SkyCity admitted that it operated in contravention of the AML/CTF Act under two different sections.

• Section 81 – its AML/CTF Programs did not meet the requirements of the AML/CTF Act and AML/CTF Rules.
• Section 36 – it did not carry out appropriate ongoing customer due diligence with respect to certain higher-risk customers and customers transacting through higher-risk channels.

Justice Lee will consider the proposed settlement between SkyCity and AUSTRAC when the court hearing takes place on June 7.

While a $67m penalty has been agreed to between the two parties in question, the court will have the final say on the appropriate penalty to be issued.

AUSTRAC’s Chief Executive Officer, Brendan Thomas, commented: “AUSTRAC took this action out of concern that SkyCity’s conduct meant that a range of high-risk practices, behaviours and customer relationships were allowed to continue unchecked for many years.”

Thomas added that the action demonstrates the importance of AML/CTF obligations to casinos and gaming companies and to be vigilant to money laundering and terrorism financing risks.

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The EGBA believes the changes will strengthen the EU’s approach to tackling money laundering and “benefit online gambling operators by standardising AML rules and reporting requirements across member states”.

With formal adoption by the Council of the EU expected in May, before being published in the EU’s Official Journal, the new package will contain:

• A single rulebook regulation – provisions on conducting due diligence on customers, transparency of beneficial owners and the use of crypto-assets.
• The sixth Anti-Money Laundering Directive – national provisions on supervision and national AML authorities, as well as on the access of authorities to necessary and reliable information, eg beneficial ownership registers.
• The establishment of the European Anti-Money Laundering Authority – AMLA – will have supervisory and investigative powers to ensure compliance with AML requirements, operating in conjunction with national AML authorities.

In addition, the EGBA noted that online gambling operators will benefit from the creation of a harmonised reporting format for suspicious transaction reports under the competence of the AMLA, having the same STR requirements across member states and “setting clear and consistent expectations that will reduce administrative burdens and costs”.

Dr Ekaterina Hartmann, Director of Legal and Regulatory Affairs of EGBA, commented: “We welcome the European Parliament’s approval of the new anti-money laundering package. The new framework will set high standards and ensure greater consistency in the application of AML rules across the EU. 

“Online gambling operators, especially those operating in multiple countries, will benefit from a single rulebook and harmonised reporting requirements that will unravel national complexities. We will look to review our industry guidelines on AML to ensure their alignment with the new EU rules.”

Last year, the EGBA developed industry-specific AML guidelines to help operators comply with the new rules. These guidelines “apply a risk-based approach and include practical measures that operators can take – on customer and business risk assessments, customer due diligence processes, suspicious transaction reporting and record-keeping”.

Members already apply the guidelines and submit annual reports to the association summarising their measure implementation progress, but these guidelines are also open to all operators based in the EU.

Hartmann concluded: “By signing up to the guidelines, operators can already prepare themselves for the incoming changes in the EU rules and join our members in their efforts to proactively and positively contribute to the EU’s fight against money laundering.”

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Following an AML compliance inspection of the operator, the orders were administered to Mr Green by the authority on April 10 for AML breaches on risk assessment, on procedures for internal controls and for failing to ensure that controls are carried out.

In addition, the reprimand was handed to the operator for breaching the rules on notification in the AML act.

Regarding insufficient risk assessment, Spillemyndigheden stated that the decision was made as “no separate risk assessment has been made of the individual identified risks associated with Mr Green’s business model, including payment solutions, and the risk factors associated with it”.

The authority noted that section 7(1) of the AML act states that undertakings subject to the act must “identify and assess the risk that the undertaking may be misused for money laundering or terrorist financing”.

The risk assessment must feature a “separate assessment of the risk of the individual payment solutions and delivery channels, as well as a separate risk assessment of the risk factors associated with these”, to which Spillemyndigheden said the operator did not comply.

Regarding insufficient and lack of business procedures, Spillemyndigheden claimed that Mr Green doesn’t have “adequate procedures for internal controls, as these do not describe the interval at which controls should be performed”, as well as no “written procedures on how to monitor that controls are carried out”.

The authority remarked that section 8(1) of the AML act states that undertakings subject to the act must have “adequate written business procedures, which must include internal control”.

In addition, business procedures should describe how listed areas are handled, and internal control also means that “there must be controls of whether the controls are being carried out” as well as being checked. 

Spillemyndigheden asserted that the operator “has not sufficiently complied with the commitments on business procedures for controls”.

Regarding lack of documentation of controls, Spillemyndigheden declared that Mr Green hasn’t “documented that controls have been carried out to verify that the internal controls have been performed”. 

The authority commented that under the same section 8(1) of the AML act, undertakings subject to the act must “document the controls that have been carried out”, which it says Mr Green has not complied with the obligations to “perform controls to ensure that the internal controls are performed”.

Regarding the reprimand for not making an immediate notification, Spillemyndigheden noted that it was given to Mr Green as the operator, in two cases, did not comply with the requirement of immediately notifying the Money Laundering Secretariat. 

The authority commented that section 26(1) of the AML act states that an undertaking “must immediately notify the Money Laundering Secretariat if the undertaking knows, suspects or has reasonable grounds to suspect that a transaction, funds or activity is or has been related to money laundering or terrorist financing”, a demand which it says Mr Green didn’t comply with.

Spillemyndigheden has instructed Mr Gren to submit a revised risk assessment by June 10, 2024, as well as a revised business procedure for internal controls and prepared business procedures for how the implementation of controls is monitored.

In addition, the operator must also submit documentation that it has been controlled and that the “controls have been carried out” to the authority by October 10, 2024.

The authority added that “the reprimand does not entail any obligation to act on the part of Mr Green Limited as the breach no longer exists”.

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The NRA is Bulgaria’s regulatory body that precedes the operator licensing process and taxation, with the news being shared during a general meeting organised by Director General Rumen Spetsov. 

As a result a variety of strategies were analysed and discussed as the industry looks to collaborate to combat money laundering and terrorism financing. 

One of the key outcomes was setting up duties of increased collaboration between NRA representatives and the gambling industry in order to solve any challenges relating to regulatory procedures and changes in the framework. 

Spetsov commented: “The NRA is focused on partnerships and is available to assist businesses when it comes to supporting their duties in relation to current legislation. 

“We value the commitment of the gambling industry to effectively counteract and prevent money laundering and terrorism financing.”

AML developments in Bulgaria are also being closely monitored by the FATF, as the country is currently on its grey list. 

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