FATF Updates High-Risk Jurisdiction Lists: What Danish Operators Need to Know

The Danish Gambling Authority (Spillemyndigheden) has drawn operator attention to the latest updates from the Financial Action Task Force (FATF) regarding high-risk jurisdictions, including both the Grey List (jurisdictions under increased monitoring) and the Black List.

EDD Requirements ClarifiedUnder section 17(1) of the Danish AML Act, gambling operators must conduct enhanced customer due diligence (EDD) when a player is assessed to present a higher risk of the operator being exploited for money laundering or terrorist financing.

Operators are required to base their risk assessments on Annex 3 of the AML Act, which outlines high-risk factors including reference to FATF's black and grey lists.

Important Distinction for Compliance TeamsThe regulator has emphasized a crucial compliance point: FATF list inclusion alone does not automatically trigger EDD requirements. Mandatory enhanced due diligence under section 17(2) of the Danish AML Act applies only to players from jurisdictions specifically listed in the EU Regulation of High Risk Third Countries.

This distinction is significant for operators managing compliance workflows, as it allows for a risk-based approach to players from FATF-listed jurisdictions rather than blanket EDD application.

Operators serving the Danish market should review their current AML procedures to ensure risk assessment frameworks properly incorporate the updated FATF lists while maintaining the correct threshold for mandatory EDD triggers.