Netherlands Prepares Slot AML Exemptions Ahead of 2027 EU Rules

The Netherlands is preparing to exempt certain low-risk gambling products, including land-based slot machines, from upcoming EU anti-money laundering (AML) rules, following new government-backed research. Findings published on April 23 by the Dutch Ministry of Justice’s research body, WODC, conclude that licensed gambling channels, particularly land-based slots and smaller games, present limited structural risk of money laundering.

The study, conducted with consultancy Dialogic, forms part of the Netherlands’ position ahead of the EU’s Anti-Money Laundering Regulation (AMLR), which comes into force on July 10, 2027. Under AMLR, member states can apply simplified due diligence or exemptions for sectors classified as low risk. According to the WODC, existing controls in the Dutch market, including customer due diligence (CDD), transaction monitoring, and strict limits on anonymous play, already mitigate most risks in regulated environments.

The report distinguishes between verticals. Lotteries, scratchcards, and land-based slot machines are consistently rated low risk, while land-based sports betting no longer qualifies for that classification. Online gambling also carries a low baseline risk in the Netherlands, though authorities note it requires stricter ongoing monitoring due to transaction speed and cross-border exposure.

Dutch State Secretary for Legal Protection Teun Struycken has indicated that the government intends to follow the WODC findings when shaping its AMLR implementation. This includes maintaining lighter requirements for low-risk segments while tightening scrutiny in areas flagged as higher risk. Secondary reporting suggests that exemptions for smaller-scale games will remain in place, while betting verticals face closer supervision.

For operators, the distinction matters. AMLR introduces a harmonised framework across the EU, replacing fragmented national approaches with directly applicable rules. At the same time, national risk classifications allow different compliance burdens across verticals within the same market.

The Netherlands already operates under the Wwft, the Money Laundering and Terrorist Financing Prevention Act, which imposes AML obligations on licensed operators. The WODC findings confirm that, within this framework, certain land-based products do not require additional layers of oversight under EU law.

💡 TGJ Take

For land-based slot operators, the WODC findings point to lighter AML obligations under AMLR and lower compliance costs from 2027. Online operators face a different reality, as low-risk classification still comes with monitoring expectations and closer regulatory attention. The result is a split compliance model within the same market, which suppliers and affiliates need to factor into product positioning and partnerships.