The Danish Gambling Authority has issued guidance on updated high-risk jurisdiction classifications from the Financial Action Task Force (FATF), reinforcing compliance obligations for gambling operators conducting customer risk assessments.
Updated FATF Classifications
FATF has refreshed both its Grey List for jurisdictions under increased monitoring and Black List for territories requiring enhanced action. The Grey List now includes 20 jurisdictions: Algeria, Angola, Bolivia, Bulgaria, Cameroon, the Ivory Coast, DR Congo, Haiti, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, Vietnam, the Virgin Islands and Yemen.
The Black List maintains three high-risk territories: Democratic People's Republic of Korea, Iran and Myanmar.
FATF List Classifications
The Financial Action Task Force maintains two key lists for AML compliance: the Grey List with 20 jurisdictions under increased monitoring, and the Black List with 3 high-risk territories requiring enhanced action. These classifications serve as risk indicators for gambling operators but do not automatically trigger enhanced due diligence requirements.
Risk Assessment Requirements
Under section 17(1) of the Danish AML Act, gambling operators must conduct enhanced customer due diligence (EDD) when players present elevated money laundering or terrorist financing risks. This assessment draws from Annex 3 of the Act, which incorporates FATF's high-risk country classifications.
However, the Danish authority clarifies that FATF list placement alone does not automatically trigger EDD requirements. Operators must perform comprehensive risk evaluations considering multiple factors outlined in the legislation, similar to approaches adopted by other EU regulators addressing AML compliance.
EDD Trigger Mechanisms
The regulatory framework establishes clear distinctions for when enhanced due diligence becomes mandatory. While FATF listings inform risk assessments, EDD obligations under section 17(2) of the Danish AML Act specifically apply to players from jurisdictions on the EU Regulation of High Risk Third Country list.
This dual-layer approach allows operators to incorporate FATF intelligence while maintaining compliance with EU-harmonized high-risk determinations that carry binding EDD requirements.
Compliance Framework Implications
The guidance reinforces Denmark's risk-based approach to AML compliance in gambling. Operators must maintain current awareness of evolving international risk assessments while applying proportionate due diligence measures based on comprehensive player risk profiles.
The distinction between FATF listings as risk indicators versus EU designations as EDD triggers provides operational clarity for compliance teams managing customer onboarding and monitoring procedures. This framework balances international intelligence sharing with standardized European enforcement mechanisms.
Compliance Best Practice
While FATF listings provide valuable risk intelligence, operators should focus their mandatory enhanced due diligence procedures on players from jurisdictions listed in EU Regulation of High Risk Third Countries. This dual-layer approach ensures compliance with binding requirements while incorporating international risk assessments into broader customer risk profiling.
According to Danish Gambling Authority.
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