Slot machines: risk reclassified in the Netherlands

In the Netherlands, a policy decision could redefine the perception of slot machines across Europe. Following an in-depth audit of money laundering risks, the authorities are considering classifying this sector as ‘low risk’. 

A regulatory turning point under European pressure

The European Union is preparing to significantly tighten its arsenal against money laundering. The new Anti-Money Laundering Regulation (AMLR), which will come into force in 2027, requires Member States to accurately assess the risks associated with each economic sector. 

Within this framework, gambling is no longer treated uniformly. National authorities may now grant exemptions to certain activities, provided they can demonstrate that their risk level is genuinely low. Slot machines, long perceived as sensitive, are currently being reassessed in the Netherlands.

A politically sensitive decision

Classifying slot machines as “low risk” remains a delicate matter, given that the gambling industry has historically been associated with risks of fraud and money laundering.

But modern regulatory frameworks have profoundly transformed practices. As Emmanuel Mewissen, CEO of the GAMING1 group, points out:

“In a regulated environment, risk is managed.”

Today, slot machine operators operate within a highly regulated environment. Several factors underpin this regulatory framework. There are a number of obligations arising from European anti-money laundering frameworks, which require, in particular, customer identification, transaction monitoring and the reporting of suspicious transactions. 

Research carried out for the Dutch government shows that the risk of money laundering depends less on the type of game than on the level of control exercised. In sectors where obligations are strictly enforced, the risk can be significantly reduced.  

Slot machines: a limited but not non-existent risk

The analyses carried out as part of the studies commissioned by the Dutch government do not conclude that there is a total absence of risk. Rather, they show that the risk is managed within a regulated environment.

The assessment framework is based on several criteria:

• the ability to inject significant funds 
• the potential return on operations 
• the probability of detection 

These factors help determine whether an activity poses a structural or merely marginal risk. In the case of slot machines, technical and regulatory constraints severely limit the possibilities for large-scale money laundering.

A European strategy: targeting the real risks

One of the key lessons from this development is the shift in regulatory philosophy.

For a long time, public policy applied uniform rules across the entire gambling sector. Today, the trend is different: the aim is to tailor regulatory requirements to the actual level of risk.

As Emmanuel Mewissen puts it:

“Better regulation does not always mean more regulation.”

The Belgian example: an already strict framework

Belgium is often cited as a model for gambling regulation. The country has one of the most rigorous regulatory frameworks in Europe. This system is based on a combination of technical controls, strict licensing and continuous monitoring. It demonstrates that regulation can be effective without being excessive, provided it is targeted.

Recognising a low risk does not mean abandoning controls. On the contrary, it is based on the idea that existing mechanisms work. The challenge for the authorities will therefore be to maintain this level of rigour whilst avoiding over-regulation that could undermine legal operators.