Anti-Money Laundering for Sports Betting Agencies

Sports betting agencies are in the spotlight twice over: as obliged entities under Section 2(1) No. 15 GwG, they are subject to the full anti-money laundering obligations – and the supervisory authorities check closely whether prevention works in everyday business. Supporting betting agencies has been our focus for years – with many locations and close exchange with the supervisory authorities.

Your obligations under the German AML Act

Obliged entity under Section 2(1) No. 15 GwG – regardless of size
AML officer at management level and a deputy (Section 7(1) GwG)
Risk assessment and internal safeguards for every location (Sections 5, 6 GwG)
Identification for winnings or stakes of €2,000 or more – including several linked transactions (Section 10(5) GwG)
Suspicious activity reports to the FIU and the prohibition of tipping-off (Sections 43, 47 GwG)
Training for all employees and an anonymous reporting channel for violations (Section 6(2) No. 6 and (5) GwG)

Typical risks in sports betting

Smurfing

Splitting stakes or payouts to stay below €2,000.

Winning receipts

Customers ask for winning receipts without placing their own bet – often to legitimise cash.

Straw men

Bets or customer cards for third parties to avoid one's own identification.

Low-risk betting strategies

High turnover with a low risk of loss, e.g. by betting on low odds or surebets.

Our service package for betting agencies

External AML officerTaking over the role, including notification to the supervisory authority.
Risk assessment & work instructionsFor all locations, understandable for staff at the counter.
Training with certificateOnline training on money laundering and addiction prevention for all employees.
Controls & audit supportRegular review of implementation and support during regulatory inspections.