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Finland’s ban on crypto-assets in licensed gambling has created the same dynamic as its bar on bonuses and affiliate marketing – namely, the measures imposed to drive up the channelisation rate could well have the opposite effect.
Jon Hautamäki, a partner with Helsinki-based Nordic Law, expressed the paradox succinctly: “Licensed operators cannot offer crypto-asset gambling. Offshore operators can, do and will. Finnish players who want to gamble with crypto-assets will simply continue to use unlicensed offshore sites.”
However, there are a number of different factors in play with the crypto-assets ban. Some had already surfaced when the act was passed at the start of 2026. The impact of others will not be clear until well after Finland’s new licensed gambling regime begins operating on July 1, 2027.
The MiCA Factor
One factor is the EU’s Markets in Crypto-Assets (MiCA) regulations to legitimise and integrate crypto into the European economy. Hautamäki said that the potential implications of MiCA on Finland’s crypto-assets ban could feature in Finnish and European courtrooms in the next few years.
Hautamäki told Vixio GamblingCompliance that his law firm had spoken with operators currently preparing their licence applications or evaluating the market and they were aware of the crypto-asset ban.
“For mainstream casino operators, the ban is noted as a constraint but is not typically a deal-breaker. Their product offering is predominantly fiat-based and the Finnish player base they are targeting is familiar with traditional payment methods”, he said.
For them, the affiliate ban and the bonus restrictions carried immediate commercial consequences because of their clear and obvious influence on player acquisition.
The outlook for operators whose core product and brand identity was based on crypto-assets was very different. In order to obtain a Finnish licence, a crypto casino operator would be required to run both an exclusively Finnish brand using fiat currency alongside a crypto-asset platform that would be barred from the country.
Hautamäki commented: “That is not an insurmountable structure, but it is a real operational and commercial decision that affects how they approach the decision of possibly applying for a licence in Finland.”
Up to now, no operator has put forward a legal argument that the crypto-assets ban is contrary to EU law; Hautamäki said it made no sense to make it while applying for a licence.
Nordic Law pointed out MiCA’s possible implications in its 2024 submission to the consultation that helped shape the Gambling Act; Finnish lawmakers looked at other factors like creating tight AML and KYC measures and real-time tracing of potentially suspicious transactions. Another factor was banning players from using credit to gamble with.
They also took the view that crypto-assets are volatile and if, for example, a player’s deposit fell in value, that created a problem in terms of keeping within the act’s mandatory limits on deposits and losses, as well as preventing harm.
Deliberate Bans
Including the three bans had been a deliberate choice. Each met the first of the two primary goals of the legislation – reducing gambling harm. That was despite the view of many, including Hautamäki, that it actively undermined the second – improving the channelisation rate.
It is expected that Finland will wait until a significant amount of data has been collected after July 1, 2027 before reassessing how the various bans have affected channelisation. It has to be said that the official statistics are not promising.
Finland's longstanding state gambling monopoly, Veikkaus, said in its 2025 annual report that Finnish players spent €903m on offshore digital gambling platforms last year out of the €1.475bn total spent nationally.
The €903m was not only a record high, it also amounted to 61 percent of the total digital gambling market in Finland. Trend-wise, the offshore spend has increased every year since 2021 when it was €518m.
Hautamäki told Vixio that if the licensed market fails to recapture a meaningful share of the money spent offshore, the political pressure to revisit the marketing framework will grow.
Further pressure for change may come from players and operators that might start using crypto-assets, saying they are permitted to do so under MiCA.
Legally, Hautamäki’s starting point was that the crypto-asset ban is Finnish law and proponents cannot reliably base their case on EU law, and if they did, it could take years to resolve.
But he added, there were two specific EU law issues with the current ban. The first was that it applied to all crypto-assets without reference to MiCA, which explicitly treats e-money tokens as equivalent to electronic money and fiat currency.
“A prohibition that treats a MiCA-regulated e-money token differently from a euro held in a bank account for the purpose of gambling transactions is difficult to reconcile with the technology-neutral principle embedded in EU law,” commented Hautamäki.
His second point was that the AML considerations Finnish lawmakers used to help frame the Gambling Act had been substantially weakened by the full implementation of MiCA from December 2024.
It meant that crypto-asset service providers were now subject to the identical AML and customer identification obligations as traditional payment service providers.
Whether or not Finland’s gamblers were permitted to use crypto-assets was not the point; the reality was they had been using them for years and the restrictions on crypto-assets, affiliates and bonuses only applied to the regulated market.
Hautamäki suggested a “credible” EU law challenge could come from an operator denied a licence on crypto-related grounds, or from a licensed operator prohibited from expanding into crypto-asset services.
He concluded: “The channelisation data after launch will determine how much political appetite there is for revisiting the provision before that kind of challenge materialises. If the data is bad – and there are legitimate reasons to think it will be – the legislature may move first.”
