SWEDEN Law and Practice Contributed by: Stefan Widmark, Hans Eriksson and Petter Larsson, Westerberg & Partners
• mandatory contact with any player increasing the limit in excess of SEK10,000 per month; • mandatory notification requirements on customer account data, including winnings, losses, session times, limits, possibilities to log out, and general RG information; and • mandatory self-exclusion tools and a hyperlink to the Spelpaus national self-exclusion register in relation to all games for a minimum of 24 hours up to indefinite exclusion. 8. Anti-Money Laundering (AML) 8.1 AML Legislation The Act (2017:630) on Measures Against Money Laun- dering and Financing of Terrorism, which has imple- mented Directive (EU) 2015/849 of the European Par- liament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (the “Fourth AML Directive”) is the central AML leg- islation. Further, the Regulation (2009:92) on Measures Against Money Laundering and Financing of Terrorism includes additional regulations on AML issues. Moreover, the SGA has issued regulations on the pre- vention of money laundering and the financing of ter- rorism (LIFS 2019:2). Lastly, in the spring of 2025, the SGA published updat- ed AML guidance, which includes useful recommen- dations on the fundamental regulatory requirements, such as registration verification, risk assessments and KYC protocols. 8.2 AML Requirements All gambling operations in Sweden are subject to the restrictions in the Act on Measures Against Money Laundering and Financing of Terrorism. The SGA has also issued binding regulations on AML measures in SIFS 2019:2 and published guidance on how licence holders should work to counteract money laundering and terror financing. In short, the following safety measures should be conducted:
• customer due diligence measures; • monitoring and reporting; • processing of personal data; • aptitude testing of staff; • compliance and internal control; and • model risk management procedures, if such mod- els are used. If the licence holder is part of a corporate group, there are special provisions on group-wide procedures, which include a requirement for parent companies to establish procedures that apply to the entire group. The SGA and the Swedish Consumer Agency jointly supervise the marketing restrictions of gambling ser- vices on the Swedish market. In brief, the SGA super- vises marketing issues that relate directly to gambling operations such as bonus campaigns, etc. The Con- sumer Agency supervises the compliance with gen- eral marketing restrictions for gambling services – for example, the requirement of moderate marketing of gambling services. The Swedish Public Prosecutor’s Office enforces criminal matters. 9.2 Definition of Advertising Under the Swedish Marketing Act, the concept of marketing is defined as “advertising and other busi- ness activities intended to promote the sale of and access to products, including a trader’s act, omission or other measure or conduct before, during or after the sale or delivery of products to consumers or traders”. In case law, the concept of advertising has been given an extensive interpretation. 9.3 Key Legal, Regulatory and Licensing Provisions The key legal provisions governing advertisement of gambling products and services are set out in the Swedish Marketing Act and in Chapter 15 of the Swedish Gambling Act. 9. Advertising 9.1 Regulatory/Supervisory Agency
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