Swedish Gambling Authority's Formalistic Approach: A Comparative Analysis

BOS Report on the Swedish Gambling Authority’s Supervisory Work

Commissioned by the Swedish Trade Association for Online Gambling (BOS), the law firm Nordic Legal has conducted a comparative study of the Swedish Gambling Authority’s (SGA’s) supervisory activities and sanction decisions. The SGA was compared with other Swedish government agencies that hold similar responsibilities.

The study reveals that the SGA differs from other Swedish agencies by employing a more formalistic approach and imposing harsher penalties.

Three aspects are analysed in the report:

1. The SGA applies a different, more formalistic, and less risk-based approach compared to other agencies that also hold supervisory responsibility for anti-money laundering measures.

2. The SGA employs a different methodology than other agencies that also assess individuals in senior management positions. The SGA places heavy emphasis on the timely submission of documentation, whereas other agencies focus primarily on the suitability of the individuals in these roles.

3. In terms of the proportion of the maximum possible penalty, the SGA imposes harsher sanction fees than other comparable government agencies.

“We believe that the licensed gambling market in Sweden would benefit if the Swedish Gambling Authority were to adopt working methods more closely aligned with those of other Swedish government agencies. This would lead to a more risk-based approach, which would strengthen efforts against money laundering and enhance other areas of supervision,” says Gustaf Hoffstedt, Secretary General of the Swedish Trade Association for Online Gambling.

“We hope that this report can serve as a basis and an inspiration for such an ambition — that the Swedish Gambling Authority might look to other Swedish government agencies in its approach to supervision and sanctions,” Hoffstedt concludes.

Read the report in English here