Dutch Regulator Exposes Major AML Gaps in Gambling Sector

dutch gambling ksa aml enforcement fincrime

This image is AI-generated.

Allegations of money laundering compliance failures have again surfaced in the Dutch online gambling sector, following recent enforcement actions by the Kansspelautoriteit (KSA). In July 2025, the regulator issued official warnings to three licensed gambling operators for serious breaches of the Money Laundering and Terrorist Financing (Prevention) Act, known locally as the Wwft. These warnings come at a time when the Netherlands is intensifying scrutiny of the gambling industry, particularly as the market continues to expand and more operators target Dutch consumers.

The flagged providers, while not named publicly by the KSA, are among the growing list of licensed operators that have been instructed to address identified failings or risk substantial financial penalties. These measures reflect the regulator’s ongoing concerns over weak transaction monitoring, insufficient due diligence, and delays in reporting suspicious activities to the Dutch Financial Intelligence Unit (FIU). The warnings also highlight broader systemic risks, as the regulator has repeatedly signaled that improvements are needed across the sector to address evolving money laundering threats.

The Dutch gambling market has become a significant focus for AML compliance, especially since the launch of regulated online gambling in 2021. The KSA’s latest actions demonstrate a willingness to enforce the Wwft robustly, in line with broader European Union expectations around the prevention of illicit finance in high-risk sectors. This article unpacks the background, regulatory expectations, and market impact of the latest enforcement wave, providing a clear view of the state of AML controls in Dutch gambling.

Dutch Gambling AML Regulation: Key Laws and Supervisory Standards

Regulatory oversight of gambling operators in the Netherlands is primarily governed by the KSA, an independent administrative body reporting to the Ministry of Justice and Security. Since the enactment of the Remote Gambling Act (Wet Kansspelen op afstand, Koa) and its integration with the Wwft, all licensed gambling companies must adhere to strict rules on anti-money laundering, including:

Comprehensive customer due diligence (CDD) on all players.
Ongoing transaction monitoring for suspicious patterns or activity.
Prompt reporting of unusual transactions to the Dutch FIU.
Documentation and internal controls to evidence compliance.

The Wwft, originally enacted in 2008 and regularly updated, aligns the Netherlands with the EU’s 6th Anti-Money Laundering Directive (6AMLD) and the Financial Action Task Force (FATF) standards. Operators are expected to employ a risk-based approach, with enhanced due diligence for higher-risk customers and transactions. This includes additional scrutiny for large deposits, high-frequency bets, or activity involving non-residents or politically exposed persons.

Failure to comply can result in a range of enforcement measures, from official warnings to hefty administrative fines, suspension of licenses, and even criminal proceedings for repeated or egregious breaches. The KSA routinely inspects gambling companies, both through scheduled audits and on the basis of consumer complaints or suspicious activity reports.

KSA Enforcement in 2025: Documented Breaches and Operator Shortcomings

In its July 2025 enforcement action, the KSA requested extensive documentation from three operators, including player files, AML policies, and risk assessment records. The investigation revealed several notable violations:

Lack of adequate monitoring: Operators failed to identify or act upon suspicious transaction patterns, such as repeated small deposits or rapid turnover of funds.
Deficient record-keeping: Some companies could not provide evidence of appropriate customer due diligence, including verification of source of funds or beneficial ownership.
Delayed reporting: Cases were identified where unusual transactions were not reported to the FIU in a timely manner, contrary to statutory obligations.
Weak policy frameworks: Internal AML policies were found to be outdated or insufficient, lacking proper risk assessment or escalation procedures.

These deficiencies mirror issues previously identified in other European gambling markets, where regulators have imposed multi-million-euro fines for similar compliance gaps. The KSA’s latest warnings carry the clear implication that, unless immediate remedial action is taken, formal penalties will follow, potentially affecting the ability of operators to continue offering services in the Dutch market.

Beyond individual operator failings, the KSA has reiterated its broader concern that systemic AML risks persist in the market. In late 2023, the regulator updated its own guidelines, drawing on research findings, industry feedback, and signals from both consumers and providers. Further guidance and best practices were shared in a public webinar in late 2024, with the aim of clarifying expectations and improving industry-wide compliance standards.

Transaction Monitoring, Reporting, and Player Protection Requirements

At the heart of AML regulation for gambling providers is the requirement to actively monitor player activity for signs of suspicious or illicit transactions. Operators must deploy technology and processes capable of identifying red flags, such as:

Unusual betting patterns or sudden spikes in wagering.
Frequent use of multiple payment methods or accounts.
Attempts to circumvent deposit and withdrawal limits.
Transactions involving high-risk jurisdictions or virtual currencies.

Upon detection of such indicators, the provider is required to investigate and, where appropriate, file a report with the Dutch FIU (FIU-Nederland). The reporting threshold is low—any transaction that appears unusual or inconsistent with the customer’s profile must be flagged, regardless of the amount involved.

Additional rules are in place to protect players from exploitation or the misuse of gambling services for money laundering. The KSA closely monitors how operators handle player balances, withdrawal requests, and customer complaints. Recent warnings issued by the regulator focused on the improper restriction of withdrawals, where one operator was found to require players to wager deposited funds before allowing payouts—a practice only permissible under specific bonus terms and strictly regulated.

Operators are reminded that player funds must always be accessible and refunded immediately upon request, with no unnecessary delays or arbitrary conditions. Any technical or procedural barriers to withdrawal are viewed as unacceptable and risk triggering regulatory intervention.

Sector-Wide Challenges and the Path to Stronger AML Controls

Despite ongoing regulatory oversight, the Dutch gambling sector continues to grapple with several persistent challenges around AML compliance. These include:

Rapid market expansion: The fast growth of online gambling in the Netherlands since 2021 has stretched the resources of both operators and the regulator, leading to uneven implementation of AML controls.
Complex payment flows: The use of multiple payment methods, including e-wallets, prepaid cards, and cryptocurrencies, complicates the task of monitoring transactions for illicit activity.
Cross-border risks: International operators and customers from neighboring countries introduce additional risks, as transactions can cross legal or regulatory boundaries.
Evolving typologies: Criminals constantly adapt their methods, using low-value, high-frequency bets, or exploiting loopholes in bonus schemes and account verification processes.

To address these challenges, the KSA and the Dutch FIU have encouraged greater investment in advanced analytics, automated monitoring tools, and staff training. Industry-wide initiatives include regular compliance workshops, updated guidance documents, and closer collaboration with law enforcement and financial sector partners.

At the same time, Dutch authorities are under increasing pressure from European counterparts and supranational bodies to demonstrate effective AML supervision in gambling. The European Commission, for example, has highlighted the sector as a priority area for risk mitigation under the 6AMLD, while FATF mutual evaluations continue to stress the need for robust controls in all high-risk industries.

The Regulatory Outlook: Upcoming Changes and Market Impact

The KSA has made it clear that enforcement will intensify in the coming months, with the threat of fines and potential license revocations for operators that do not demonstrate full compliance. The Dutch market is seen as a test case for effective AML regulation in gambling, especially as other EU states seek to modernize their own frameworks.

Several important developments are expected in the near term:

More frequent inspections: The KSA is increasing the frequency and depth of operator audits, with a particular focus on transaction monitoring systems and unusual activity reporting.
New guidance and risk typologies: Updated regulatory guidance is anticipated, reflecting recent typologies and best practices identified at both national and European levels.
Closer cross-border cooperation: The Dutch FIU is collaborating more closely with counterparts in Belgium, Germany, and the UK, sharing information on emerging risks and joint investigations.
Technology-driven compliance: Operators are being urged to deploy more sophisticated tools for customer identification, source-of-funds verification, and automated alert handling.

For operators, these changes will require continued investment in compliance infrastructure, staff training, and regular policy updates. Failure to adapt may not only result in regulatory penalties, but also reputational damage and loss of market access.

Conclusion: Lessons and Next Steps for Dutch Gambling AML Compliance

The latest actions by the Dutch gambling regulator underscore the heightened scrutiny facing the sector and the urgent need for effective anti-money laundering controls. The warnings issued in July 2025 serve as a clear reminder that both systemic and operator-level failings can have significant consequences, from financial penalties to reputational harm and regulatory exclusion.

Moving forward, Dutch gambling operators must prioritize robust transaction monitoring, timely reporting of suspicious activity, and a proactive approach to emerging risks. Investments in technology, staff training, and regular policy reviews will be essential to keep pace with both regulatory expectations and the evolving tactics of financial criminals.

For the Dutch market as a whole, maintaining the confidence of regulators, players, and partners requires a shared commitment to compliance and transparency. As the KSA continues to raise the bar, the gambling sector’s ability to adapt and respond to new AML challenges will determine its long-term sustainability and reputation.

Source: Focus Gaming News

Some of FinCrime Central’s articles may have been enriched or edited with the help of AI tools. It may contain unintentional errors.

Want to promote your brand with us or need some help selecting the right solution or the right advisory firm? Email us at info@fincrimecentral.com; we probably have the right contact for you.