EU Anti-Money Laundering Authority (AMLA) and Gambling: How the New AML Supervisory Framework Affects EU Gambling Operators

Introduction: The EU AML Package and Gambling

The European Union's new Anti-Money Laundering Package represents the most significant overhaul of AML regulation in the EU's history. At its center is AMLA — the Anti-Money Laundering Authority — a new EU agency with direct supervisory powers over high-risk obliged entities, including qualifying gambling operators.

For the gambling industry, which has long been classified as a high-risk sector for money laundering across EU risk assessments, AMLA's establishment marks a fundamental shift from purely national supervision to a hybrid model combining EU-level oversight with continued national regulation. This transformation affects everything from compliance structures to reporting relationships and enforcement exposure.

The AML Package comprises several interconnected regulations that collectively reshape gambling compliance obligations. Understanding how these components interact is essential for operators navigating the new supervisory landscape, compliance officers adapting internal frameworks, and legal professionals advising gambling businesses on regulatory strategy.

Understanding AMLA: Structure and Powers

Establishment and Location

AMLA was formally established by Regulation (EU) 2024/1620 and is headquartered in Frankfurt, Germany. The decision to locate AMLA in Frankfurt, a major financial center already hosting the European Central Bank, reflects the authority's primary focus on financial sector supervision while accommodating its broader mandate covering gambling and other obliged entities.

AMLA operates as an independent EU agency with its own legal personality, budget, and governance structure. The authority is led by an Executive Board and overseen by a General Board comprising representatives from national AML supervisors and Financial Intelligence Units (FIUs) across all member states.

Core Functions

AMLA's mandate encompasses several interconnected functions affecting gambling operators:

• Direct supervision: AMLA directly supervises selected high-risk obliged entities, including gambling operators meeting specific criteria
• Indirect supervision: AMLA coordinates and oversees national supervisors responsible for entities not directly supervised by AMLA
• FIU coordination: AMLA supports and coordinates the work of national Financial Intelligence Units, facilitating cross-border information sharing
• Technical standards: AMLA develops binding regulatory and implementing technical standards adopted by the European Commission
• Risk assessment: AMLA contributes to EU-level money laundering risk assessments and guidance on sectoral risks, including gambling

Direct vs. Indirect Supervision

The distinction between direct and indirect supervision is critical for gambling operators. Directly supervised entities face AMLA inspections, must submit documentation directly to AMLA, and are subject to AMLA enforcement actions. Indirectly supervised entities remain under national supervisor authority but must comply with AMLA-issued technical standards and may be subject to AMLA peer reviews of their national supervisors.

For gambling operators, this creates a tiered system where the largest cross-border platforms face EU-level oversight while smaller or single-jurisdiction operators continue under national supervision — albeit with harmonized requirements.

Which Gambling Operators Will AMLA Directly Supervise?

Selection Criteria

AMLA's direct supervision mandate prioritizes entities presenting the highest cross-border money laundering risks. For gambling operators, selection depends on several cumulative criteria:

The initial selection cycle, beginning in 2025-2026, prioritized credit institutions given the financial sector's systemic importance. Subsequent cycles will incorporate other obliged entities, including gambling operators meeting the selection criteria. This phased approach means most gambling operators will first experience AMLA's impact through harmonized standards before any face direct supervision.

Practical Implications for Selected Operators

Gambling operators selected for direct AMLA supervision face significant operational changes:

• Dedicated compliance interface: A designated AMLA supervisory team becomes the primary AML contact, replacing national supervisor relationships
• Approval requirements: AML policies, risk assessments, and significant changes require AMLA approval
• On-site inspections: AMLA conducts comprehensive AML inspections, potentially with national supervisor participation
• Reporting obligations: Direct reporting to AMLA on AML matters, in addition to continued national licensing requirements
• Enforcement exposure: Subject to AMLA's substantial penalty powers, including fines up to 10% of annual turnover

Operators should assess whether they meet or approach the selection thresholds and prepare for potential AMLA supervision accordingly. Even operators not immediately selected may face selection in subsequent cycles as their cross-border footprint expands.

The AML Regulation: Direct Applicability for Gambling

From Directive to Regulation

Perhaps the most significant technical change in the AML Package is the shift from a directive (requiring national transposition) to a directly applicable regulation. The Anti-Money Laundering Regulation (AMLR) creates uniform rules across all 27 member states, eliminating implementation variations that previously created compliance complexity for cross-border operators.

For gambling operators, this means identical AML requirements apply whether operating in Malta, Germany, or any other EU jurisdiction. While national gambling regulators retain authority over licensing and player protection, AML compliance becomes genuinely harmonized.

Key Requirements Affecting Gambling

The AMLR codifies and strengthens several requirements particularly relevant to gambling operators:

Customer Due Diligence (CDD)

The AMLR maintains gambling as a high-risk sector requiring enhanced due diligence measures. Key CDD provisions include:

• Verification timing: Customer identity verification must occur before establishing the business relationship or enabling gambling transactions
• Source of funds: Enhanced scrutiny of customer funds, particularly for high-value transactions or customers showing risk indicators
• Ongoing monitoring: Continuous transaction monitoring with documented risk-based approach
• Beneficial ownership: For corporate customers, identification and verification of beneficial owners

These requirements build upon existing frameworks but with enhanced specificity and directly applicable obligations. The enhanced due diligence and source of funds requirements we've previously covered become further codified under the AMLR.

Suspicious Activity Reporting

The AMLR strengthens suspicious activity reporting obligations with direct implications for gambling operators:

• Reporting thresholds: Lower thresholds for reporting suspicious transactions in high-risk sectors
• Reporting timeframes: Stricter deadlines for submitting suspicious activity reports to FIUs
• Cross-border coordination: Enhanced information sharing through AMLA's FIU coordination mechanism
• Feedback mechanisms: Improved feedback from FIUs on reported suspicious activities

Internal Controls and Governance

The AMLR mandates comprehensive internal control frameworks:

• AML officer requirements: Designated compliance officer with direct board reporting lines
• Board responsibility: Senior management accountability for AML compliance
• Training programs: Regular AML training for all relevant staff
• Independent audit: Periodic independent assessment of AML controls

These governance requirements align with the broader AML compliance framework gambling operators must maintain but establish more detailed specifications.

AMLA's Role in FIU Coordination

The FIU Support Mechanism

Beyond direct supervision, AMLA serves as a coordination hub for the EU's 27 Financial Intelligence Units. This coordination function has significant implications for gambling operators' suspicious activity reporting and information requests.

AMLA hosts and operates FIU.net, the secure communication network enabling FIUs to exchange information on suspicious transactions. Enhanced interoperability means that suspicious activity reports filed with one national FIU can more easily be shared across borders, improving detection of cross-border money laundering through gambling channels.

Joint Analysis and Cross-Border Cases

AMLA facilitates joint analysis of cross-border suspicious activities. For gambling operators with multi-jurisdiction presence, this means:

• Coordinated information requests: Potential for joint requests from multiple FIUs through AMLA coordination
• Pattern detection: Enhanced ability to detect patterns across jurisdictions that might indicate money laundering through gambling
• Consistent treatment: More consistent handling of cross-border cases reducing regulatory arbitrage

Implications for Operators

The enhanced FIU coordination affects gambling operators in several practical ways:

• Response capacity: Operators should ensure capacity to respond to coordinated information requests potentially involving multiple jurisdictions
• Record-keeping: Comprehensive records that can satisfy requests from any EU FIU
• Reporting consistency: Consistent reporting practices across jurisdictions to avoid gaps that might attract scrutiny

AMLA Technical Standards for Gambling

Binding Requirements

AMLA develops regulatory technical standards (RTS) and implementing technical standards (ITS) that, once adopted by the European Commission, become binding on all obliged entities, including gambling operators. These standards provide detailed specifications for AMLR requirements.

For gambling, anticipated technical standards cover:

• Risk assessment methodology: Standard frameworks for assessing customer, product, and geographic money laundering risks
• Enhanced due diligence triggers: Specific circumstances requiring enhanced due diligence in gambling contexts
• Transaction monitoring: Minimum standards for automated transaction monitoring systems
• Reporting formats: Standardized suspicious activity report formats facilitating cross-border analysis

Guidance and Opinions

Beyond binding standards, AMLA issues guidance documents and opinions interpreting AMLR requirements. While not legally binding in themselves, AMLA guidance carries significant weight and creates supervisory expectations.

Gambling-specific guidance addresses:

• Sector risk indicators: Money laundering risk indicators specific to online and land-based gambling
• Typologies: Common money laundering methods observed in gambling and detection approaches
• Best practices: Recommended practices for gambling AML compliance

Enforcement Powers and Penalties

AMLA's Direct Enforcement Authority

For directly supervised entities, AMLA possesses substantial enforcement powers:

These penalty levels significantly exceed those available to many national gambling regulators on AML matters, creating substantial financial exposure for directly supervised operators.

Coordination with National Enforcement

For indirectly supervised gambling operators, national supervisors retain enforcement authority. However, AMLA influences national enforcement through:

• Supervisory convergence: AMLA promotes consistent supervisory approaches across member states
• Peer reviews: AMLA conducts peer reviews of national supervisors, including gambling regulators' AML oversight
• Enforcement coordination: AMLA can request national supervisors to investigate or take action in specific cases

The interaction between AMLA and national regulators creates potential for both enhanced enforcement consistency and complexity as operators navigate dual oversight.

Interaction with National Gambling Regulators

Complementary Supervisory Mandates

AMLA's establishment does not replace national gambling regulators. Instead, it creates complementary supervisory mandates:

Information Sharing Between Regulators

AMLA and national gambling regulators must share information relevant to their respective mandates. This creates information flows in both directions:

• AMLA to national regulators: AML findings that may affect licensing suitability or operational fitness
• National regulators to AMLA: Gambling-specific risk information relevant to AML supervision

Operators should anticipate that information provided to either authority may be shared, affecting how they approach regulatory interactions.

Implementation Timeline and Preparation

Key Milestones

The AML Package implementation follows a phased timeline:

• 2024: AMLA formally established and begins staffing; AMLR and AMLD6 adopted
• 2025: AMLA selection process for first cohort of directly supervised entities; development of key technical standards
• 2026: Direct supervision begins for first selected entities; AMLR becomes fully applicable
• 2027-2028: Subsequent selection cycles potentially including gambling operators; full AMLA operational capacity

Preparation Checklist for Gambling Operators

Gambling operators should undertake systematic preparation:

Country-Specific Considerations

Variation in National Implementation

While the AMLR creates directly applicable rules, some aspects interact with national gambling regulation in jurisdiction-specific ways. Operators should consider:

• Dual reporting: Some jurisdictions may require parallel reporting to gambling regulators and FIUs
• Enhanced national requirements: Member states may maintain stricter requirements than AMLR minimums
• Regulatory culture: National supervisory approaches to AML in gambling vary despite harmonized rules

Our country-by-country guides will be updated to reflect how each member state's gambling regulatory framework interacts with the AMLA regime.

High-Risk Jurisdictions and Third-Country Operators

AMLA's role extends to identifying high-risk third countries and coordinating responses. Gambling operators with connections to jurisdictions on the EU high-risk third country list face enhanced due diligence requirements and potential restrictions.

Third-country gambling operators serving EU customers must ensure their AML frameworks meet EU standards, particularly if seeking licensing in EU jurisdictions or providing services to EU-licensed operators.

Practical Compliance Strategies

Building AMLA-Ready Compliance Programs

Operators should adopt compliance strategies anticipating the AMLA framework:

Risk-Based Approach

The AMLR emphasizes risk-based compliance. Operators should:

• Conduct comprehensive business-wide risk assessments documented to AMLA standards
• Implement risk-based customer due diligence calibrated to assessed risks
• Allocate compliance resources proportionate to identified risks
• Regularly review and update risk assessments reflecting changing risk profiles

Technology Investment

AMLA technical standards increasingly assume technological capabilities. Operators should invest in:

• Automated transaction monitoring with configurable rule sets
• Customer risk scoring systems
• Case management for suspicious activity investigation
• Reporting systems meeting AMLA format requirements

The emerging use of AI in gambling compliance offers opportunities to enhance detection capabilities while meeting AMLA expectations.

Documentation and Record-Keeping

AMLA supervision requires comprehensive documentation:

• Customer due diligence records retained for regulatory timeframes
• Transaction records with audit trails
• Risk assessment documentation and updates
• Policy versions and approval records
• Training records for all relevant staff

Related Resources

For comprehensive understanding of how AMLA fits within the broader EU gambling regulatory landscape, explore these related topics:

• Gambling and Money Laundering: AML Compliance Requirements in the EU
• Enhanced Due Diligence and Source of Funds Checks in EU Gambling
• EU Gambling Regulatory Cooperation and Cross-Border Enforcement
• Gambling Operator Fines and Sanctions in the EU
• Payment Blocking and AML: Why EU Gambling Transactions Fail