The Danish Gambling Authority has issued guidance on updated Financial Action Task Force (FATF) lists affecting anti-money laundering compliance for gambling operators across Denmark.
FATF List Classifications
The FATF maintains two critical risk categories: the Grey List for jurisdictions under increased monitoring and the Black List for jurisdictions requiring calls for action. Gambling operators must incorporate these designations into player risk assessment frameworks.
Currently, 22 jurisdictions appear on the Grey List: Algeria, Angola, Bolivia, Bulgaria, Cameroon, the Ivory Coast, DR Congo, Haiti, Kenya, Kuwait, Laos, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, the Virgin Islands and Yemen.
The Black List contains three jurisdictions: Democratic People's Republic of Korea, Iran and Myanmar.
22
Jurisdictions on FATF Grey List
3
Jurisdictions on FATF Black List
Compliance Requirements
Gambling operators must include FATF's lists of high-risk jurisdictions when risk assessing players. Enhanced customer due diligence (EDD) is required pursuant to section 17(1) of the Danish AML Act if a player is assessed to pose a higher risk of money laundering or terrorist financing.
Risk assessments must be based on Annex 3 to the AML Act, which incorporates FATF high-risk country lists. However, EDD is not automatically required simply because a country appears on FATF lists – it is only mandatory for players from jurisdictions listed in the EU Regulation on High-Risk Third Countries list pursuant to section 17(2) of the AML Act.
Critical Compliance Distinction
Enhanced customer due diligence (EDD) is not automatically required simply because a country appears on FATF lists. EDD is only mandatory for players from jurisdictions listed in the EU Regulation on High-Risk Third Countries list pursuant to section 17(2) of the Danish AML Act.
Regulatory Implications
This guidance clarifies a critical distinction for operators: FATF listing triggers risk assessment obligations but not automatic enhanced due diligence procedures. The regulatory framework requires operators to evaluate multiple risk factors beyond FATF designations when determining appropriate customer monitoring levels.
The FATF Updates High-Risk Jurisdictions List for AML Compliance have broader implications across European gambling markets, with operators in multiple jurisdictions adjusting their risk assessment protocols.
FATF listing triggers risk assessment obligations but not automatic enhanced due diligence procedures
According to Danish Gambling Authority.
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