The Swedish Administrative Court of Appeal has upheld the Gambling Authority’s finding that AB Trav och Galopp (ATG) breached the Money Laundering Act, though it reduced the company’s fine from SEK6 million to SEK3 million. The court’s decision confirms that ATG’s due diligence processes and customer monitoring were inadequate but stops short of classifying the failings as systematic.
The ruling follows a detailed supervisory review conducted by the Swedish Gambling Authority (SGA) between 2020 and 2022, which examined ATG’s anti-money laundering and counter-terrorism financing procedures. Investigators found repeated deficiencies in the operator’s verification of customer fund sources, handling of high-value accounts, and documentation of risk classifications.
One case revealed customer deposits exceeding SEK50 million, without adequate proof of income or background verification. The regulator also noted that ATG accepted unverifiable claims of private income, failed to act on warning indicators, and demonstrated poor record-keeping.
In response, ATG argued that the shortcomings stemmed from procedural gaps rather than intentional neglect and has since implemented significant compliance reforms. These include automated monitoring systems, enhanced KYC protocols, and a dedicated department for due diligence oversight.
The appeal court’s judgment, while offering partial relief in the reduced fine, reinforces the accountability of licensed operators to maintain robust AML controls. For Sweden’s iGaming sector, the case underscores that even isolated compliance failures can lead to substantial regulatory action and reputational risk.
