Dutch Online Gambling Faces Renewed Scrutiny Over Money Laundering Failures

In July 2025, the Kansspelautoriteit (KSA), the Netherlands’ gambling regulator, issued formal warnings to three licensed online gambling operators for serious violations of the Money Laundering and Terrorist Financing (Prevention) Act, or Wwft. Though the operators remain unnamed, the action signals a clear escalation in regulatory scrutiny as the Dutch gambling market continues to expand, and financial crime risks become more sophisticated. These enforcement steps underscore persistent shortcomings in compliance with AML laws and show that Dutch authorities are intent on tightening oversight across the sector.

According to the KSA, the operators failed to maintain effective transaction monitoring systems, exhibited weak customer due diligence (CDD) protocols, and neglected their obligation to report suspicious transactions to the Dutch Financial Intelligence Unit (FIU) in a timely manner. These failures, the regulator emphasized, highlight the broader systemic vulnerabilities that continue to plague the Dutch gambling industry. “The signals are clear,” said a KSA spokesperson. “Operators must improve their AML controls or face significant consequences.”

The Dutch market has seen a rapid transformation since the legalization of online gambling in 2021 under the Remote Gambling Act (Koa). As part of their license obligations, operators must comply with the Wwft, which mandates a risk-based approach to money laundering prevention. This includes robust CDD for all players, constant transaction monitoring, prompt and accurate reporting to FIU-Nederland, and detailed record-keeping to document compliance efforts. These standards are aligned with the EU’s 6th Anti-Money Laundering Directive (6AMLD) and the international recommendations issued by the Financial Action Task Force (FATF).

KSA’s July action followed a demand for comprehensive documentation from the three operators in question. This included internal AML policies, player due diligence records, and risk assessment frameworks. Investigators uncovered a range of concerning issues. Operators had failed to flag repetitive low-value deposits or unusually rapid movement of funds, had outdated or insufficient internal policies, and in some cases could not provide evidence that basic identity checks had been performed. Furthermore, some transactions that clearly warranted FIU notification had gone unreported for significant periods, in direct violation of legal obligations.

One particularly troubling discovery was that some operators had not updated their AML policies to account for emerging risk typologies or new technologies. “Internal frameworks were in some cases outdated, lacking both proper escalation procedures and risk-specific measures,” noted the regulator. The KSA also reiterated its longstanding concerns that AML weaknesses may be more widespread in the sector than previously reported.

This is not the first time Dutch authorities have flagged AML risks in gambling. In 2023, the KSA released updated guidance based on national research, public consultations, and input from licensed providers. Further clarifications followed in a 2024 webinar aimed at enhancing industry understanding of compliance expectations. Still, the 2025 enforcement action suggests that these efforts have not fully translated into effective implementation at the operator level.

Transaction monitoring remains a cornerstone of AML enforcement in the sector. Operators must deploy systems that can detect red flags, including atypical wagering patterns, the use of multiple accounts or payment methods, and attempts to circumvent financial controls. Suspicious activity must be reported immediately to FIU-Nederland. The reporting threshold is intentionally low—any transaction that appears inconsistent with the customer’s known behavior should be flagged, regardless of size.

The KSA also criticized some operators for restricting player withdrawals without legal basis. In one case, a provider required customers to wager deposited funds before releasing payouts—a practice only acceptable under specific bonus conditions and not applicable to regular deposits. The regulator emphasized that “player funds must be fully accessible, without delay or arbitrary conditions.” Any technical or procedural barrier to withdrawal, it warned, could lead to sanctions.

The Dutch gambling market is facing mounting AML challenges. Rapid expansion since 2021 has stretched resources on both sides—operators and regulators alike. Complicating matters further is the increasing use of non-traditional payment methods, including e-wallets, prepaid instruments, and cryptocurrencies. These channels, while convenient for users, introduce complexity and opacity into transaction flows, making it more difficult to detect illicit finance.

Cross-border activity is another area of concern. Players from neighboring countries, as well as foreign-based operators serving Dutch consumers, create additional compliance risks. Criminals are also evolving their tactics, using schemes like high-frequency micro-betting, abuse of promotional offers, and incomplete identity verification to move money through gambling platforms.

In response, the KSA and FIU-Nederland have urged operators to invest in advanced analytics, automated detection tools, and extensive staff training. National initiatives now include regular AML workshops, new guidance materials, and enhanced cooperation with financial institutions and law enforcement agencies. Dutch authorities also face pressure from European regulators to demonstrate meaningful supervision over the sector. The European Commission continues to identify gambling as a high-risk area under the 6AMLD, and FATF mutual evaluations repeatedly stress the importance of strong enforcement in digital entertainment industries.

Looking ahead, the regulatory environment will only become more demanding. The KSA has already signaled more frequent inspections and deeper audits of operators' transaction monitoring systems. Updated AML guidance reflecting new typologies and enforcement expectations is expected later this year. Authorities are also ramping up cross-border collaboration with counterparts in Germany, Belgium, and the UK to better understand international risks and coordinate investigations.

Technology will play a major role in shaping the future of compliance. Operators are being strongly encouraged to deploy tools for real-time customer identity verification, source-of-funds analysis, and machine-driven alert triaging. Those that fail to modernize their compliance infrastructures risk not only financial penalties but also reputational damage and potential loss of their licenses.

The message from the Dutch gambling authority is clear: AML compliance is not optional, and the bar for acceptable performance is rising. July’s warnings are just one step in a broader campaign to bring the industry into full alignment with national and European standards. For operators, now is the time to act. Comprehensive risk assessments, ongoing monitoring upgrades, and continuous staff education must become core elements of daily operations.

As the KSA continues to elevate its enforcement posture, the industry must prove it is capable of managing financial crime risk in a fast-evolving digital environment. Long-term viability—and public trust—depends on it.

By fLEXI tEAM