The Dutch regulator has found serious gaps between Unibet's stated anti-money laundering policies and what it actually does in practice. And Unibet may not be the only operator in the crosshairs.
The Netherlands Gambling Authority has moved against one of the Dutch market's most prominent operators, ordering Unibet to bring its anti-money laundering processes into line with both national law and its own internal policies. The action against Optdeck Service Limited, the entity through which Unibet operates in the Netherlands, centres on a gap that regulators find particularly concerning: the difference between what an operator's compliance documentation says it does and what it actually does when a real customer is sitting in front of it.
The KSA's investigation found that Unibet was in breach of the Wwft, the Netherlands' Anti-Money Laundering and Counter-Terrorism Financing Act, with customer due diligence identified as a core area of concern. More specifically, the regulator determined that the operator's transaction monitoring systems and associated controls were not functioning in accordance with its own stated policy. That distinction matters. A gap between policy and practice is not simply a technical compliance failure. It suggests that the controls an operator has committed to on paper are not being applied consistently at the operational level, which is precisely where money laundering risk is most acute.
The KSA raised particular concerns about the financial thresholds Unibet was using and the point at which a customer would be identified as presenting a high AML risk, triggering source of funds investigations. If those thresholds are set too high, or applied inconsistently, a significant volume of suspicious activity can pass through undetected before any enhanced due diligence is triggered.
The regulator's statement was direct on the broader obligation: gambling providers must monitor player behaviour and take action when unusual patterns emerge. Large deposits, even those arriving from a player's own bank account, were cited explicitly as a risk indicator that operators are expected to treat seriously. The KSA noted it had previously flagged this specific risk in its Wwft guidelines, making Unibet's shortcomings in this area harder to characterise as an oversight.
On a more constructive note, the KSA acknowledged that Unibet was cooperative throughout the investigation and implemented several changes before the process was completed. The regulator has committed to following up with the operator to verify that the remediation plan is being maintained and that the required amendments have been fully embedded in practice rather than simply documented.
Unibet's situation may be only the most visible part of a broader compliance picture in the Dutch market. The KSA confirmed it is conducting ongoing investigations into similar AML issues with other operators, framing this as part of a long-term strategy to prevent money laundering and underlying criminal activity within the regulated sector. TOTO Online received a warning for breaching the same legislation late last year, and the combination of that action and the Unibet order suggests the KSA is working systematically through the market rather than responding to isolated incidents.
The Policy-Practice Gap Is the Most Dangerous Compliance Failure
Regulators across Europe have become increasingly sophisticated in how they assess AML compliance, and the gap between documented policy and operational reality is now one of their primary areas of scrutiny. An operator that has no AML policy is obviously non-compliant. But an operator whose written policy is comprehensive and whose actual systems fall short of implementing it presents a different and in some ways more troubling picture. It suggests either that the compliance function lacks the operational authority to enforce its own standards, or that commercial pressures are allowing exceptions that the policy does not permit. The KSA's findings against Unibet point squarely at this dynamic, and it is a finding that should prompt every licensed operator in the Netherlands to conduct an honest internal audit of whether their transaction monitoring is actually doing what their policy documents claim.
The KSA Is Building a Systematic AML Enforcement Record
The actions against TOTO Online late last year and Unibet now, combined with the confirmation of ongoing investigations across the market, indicate that the KSA is pursuing a deliberate and structured approach to AML enforcement rather than reacting to individual tip-offs or complaints. That pattern of behaviour from a regulator sends a clear signal to the entire licensed market: AML compliance is being actively tested, not simply declared. Operators in the Netherlands that have not recently stress-tested the alignment between their stated policies and their actual transaction monitoring practices are taking a risk that is becoming progressively less acceptable as the KSA's enforcement programme matures.
Source of Funds Scrutiny Is Becoming Non-Negotiable Across Europe
The KSA's specific emphasis on large deposits and the threshold at which source of funds investigations are triggered reflects a regulatory consensus that is hardening across European gambling markets. The era in which an operator could justify accepting large deposits from a player's bank account without deeper scrutiny on the basis that the funds appeared legitimate at the point of transfer is effectively over. Regulators have consistently found that the most significant money laundering risks in the gambling sector occur not through obviously suspicious behaviour but through apparently normal transactions that are never examined closely enough. The Dutch regulator's focus on thresholds and trigger points is the practical expression of that understanding, and operators across Europe should expect their own regulators to apply increasingly similar standards in the months ahead.
