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Why outsource the compliance officer in Finland
Finland opens its online casino and betting market to licensed operators on 1 July 2027, and every licence holder becomes an AML obliged entity supervised by the Finnish Supervisory Agency (Lupa- ja valvontavirasto). Most operators entering the market do not have an AML professional with Finnish market knowledge on staff, and hiring one full-time for a new market is slow and expensive.
An outsourced compliance officer solves three problems at once:
- Language: the licence application is filed in Finnish or Swedish, and the supervisor and the FIU are Finnish authorities. An officer who works in Finnish removes a constant source of delay.
- Experience from day one: a professional who already knows Finnish AML practice, instead of building it up while the market opens.
- Cost: the hours the role really needs, instead of a full-time hire before the business has volume.
What the law allows
The EU AML Regulation, which applies directly from 10 July 2027, names gambling providers as obliged entities and requires two roles: a compliance manager from the management body, and a compliance officer who carries out AML day to day and reports suspicious transactions to the FIU. Where size and risk justify it, one person can hold both roles.
- Appointed by your board: the management body appoints the compliance officer. The Regulation sets standing and competence requirements, not residence or full-time employment, and Finnish law adds no such rule.
- Acting in your name: an external professional appointed as your compliance officer files the reports to the FIU and signs off as your officer. That keeps FIU reporting and the key approvals, which the Regulation does not allow to be handed to a service provider, inside your company.
- Support tasks can be outsourced: customer due diligence reviews, transaction monitoring and screening can be done by a service provider, with prior notice to the supervisor and with your company staying responsible.
The supervisor and the EU AML Authority have not yet published detailed guidance on external compliance officers for gambling operators, so we set the role up to hold on the text of the law today: a named person appointed by your board, with documented authority, full access to your systems and data, and a clear reporting line to the compliance manager.
What the outsourced compliance officer does
- Keeps the AML risk assessment, policies and procedures up to date and brings them to the board for approval
- Oversees customer due diligence and the monitoring of players and transactions
- Investigates unusual activity and files suspicious transaction reports with the FIU without delay
- Answers the supervisor’s and the FIU’s questions, in Finnish
- Trains your staff and reports regularly to the compliance manager and the board
Setting it up before the market opens
The best time to bring in the compliance officer is during the licence application. The application has to describe your customer due diligence, monitoring and reporting, and a risk assessment sized to your business and to Finnish risks, and the person who will run the framework is the right one to write it.
- During the application: AML risk assessment and procedures prepared in Finnish, with the officer named in your plans.
- Before 1 July 2027: board appointment, access to systems and data, reporting set up with the FIU, staff trained.
- From 10 July 2027: compliance manager and compliance officer in place under the EU AML Regulation.
What is at stake
Under the Finnish AML Act the supervisor can impose an infringement fee of €5,000 to €100,000 on a company, and a penalty payment for serious, repeated or systematic breaches of up to twice the benefit gained or €1 million, whichever is higher, also on managers personally. Repeated or serious AML breaches can ultimately cost the gambling licence.
How MAXCORP provides your outsourced compliance officer
MAXCORP provides a fully outsourced compliance officer for Finnish gambling operators, with Finnish-resident, Finnish-speaking personnel. Our officer is appointed by your board and works in your name, supported by our AML team for KYC reviews, monitoring and screening. We also prepare the AML part of your licence application, so the framework the officer runs is the one the supervisor approved.
See Compliance Officer outsourcing for how we work and the Finland gambling licence for the licence itself. Operating in Estonia too? Read about the Estonian FIU contact person.
Official sources (6)
- Gambling Act 10/2026 (Rahapelilaki), Finlex
- Act Amending the AML Act 13/2026, Finlex open data
- AML Act 444/2017, consolidated, Finlex open data
- Police Board regulation on the gambling licence application (11.2.2026)
- Regulation (EU) 2024/1624 (EU AML Regulation)
- Government proposal HE 105/2026 (new AML Act)
General information only, not legal or tax advice. Rules change; ask us about your case.