EU AML Package Creates a Shared Compliance Layer for Gambling
The EU’s AMLR shifts core AML/CFT obligations from a directive-based model to rules that apply directly across the member states. Gambling providers will remain classified as obliged entities under the new framework. The regulation will apply from July 10, 2027.
A Single Rulebook Reaches Gambling
The AMLR also defines a gambling service for EU AML/CFT purposes. The definition covers lotteries, casino games, poker, and betting offered at a physical location or remotely. Gambling providers must apply customer due diligence when a player collects winnings, places a stake, or does both in transactions amounting to at least €2,000. The threshold can be reached through one operation or several linked transactions.
Member states may grant full or partial exemptions to gambling services that present a proven low money-laundering risk. Casinos and operators whose principal activity is online gambling or sports betting generally cannot receive such exemptions. Limited exceptions remain possible for state-operated online gambling or services whose organisation and administration are regulated by the state. Proposed exemptions must also be approved by the European Commission.
Licensing Rules Stay National
The AML package does not establish a European gambling licence. Directive (EU) 2024/1640 requires member states to ensure that all gambling service providers are regulated. Its recitals also state that national restrictions must pursue a general-interest objective, be non-discriminatory, and remain proportionate to that objective.
It means that the EU will get dual regulation: AML regulations are increasingly standardized, while market access remains fragmented. Thus, a company can follow the single rule for financial crime but be subject to different licensing requirements in Germany, Austria, Malta, and elsewhere.
The split is also visible in the dispute over Malta’s restrictions on the enforcement of judgments issued in other EU member states against Malta-licensed gaming companies. The Commission opened an infringement procedure against Malta in June 2025.
Banks Could Drive Practical Change
The new EU Anti-Money Laundering Authority will directly supervise selected high-risk credit and financial institutions, not gambling firms. Its decisions might still affect operators via payment processors and banking institutions.
Financial institutions selected for direct AMLA supervision will face EU-level reviews of their AML controls. This could lead to closer checks on gambling clients, transaction monitoring, and reviews of operators’ licensing exposure (especially where activity crosses several national markets).
Expert View
The AML package does not settle Europe’s long-running licensing conflicts. It does, however, narrow the compliance differences that operators can rely on from one country to another. From 2027, gambling groups will need systems built for a direct EU rulebook, while still managing local licences and court disputes market by market. The first real harmonisation may arrive through compliance teams and payment relationships, rather than through a dedicated gambling directive.