Denmark Updates AML Guidance After FATF Changes

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Danish Gambling Authority Updates FATF High-Risk Country Lists – What the AML Changes Mean for Gambling Operators

Key Takeaways

The Danish Gambling Authority updated its AML guidance on March 6, 2026 following revisions to the FATF high-risk jurisdiction lists.
Kuwait and Papua New Guinea were added to the FATF Grey List after the February Plenary in Mexico City.
The FATF Black List remains unchanged and includes DPRK, Iran, and Myanmar.
Danish gambling operators must consider FATF listings in risk assessments but Grey List status does not automatically require Enhanced Customer Due Diligence.
Enhanced Customer Due Diligence is mandatory for jurisdictions listed under the EU Regulation of High-Risk Third Countries.

Spillemyndigheden Aligns Guidance With Latest FATF Decisions

The Danish Gambling Authority, known as Spillemyndigheden, has revised its compliance guidance for licensed gambling operators following updates to the Financial Action Task Force lists of high-risk jurisdictions. The update was issued on March 6, 2026 and reflects changes adopted during the FATF Plenary meeting held in Mexico City in February.

The FATF lists, commonly referred to as the Black List and the Grey List, are used internationally to identify jurisdictions with strategic deficiencies in their frameworks for combating money laundering and terrorist financing. For Danish gambling operators, these lists form part of the risk assessment process required under the Danish Anti-Money Laundering Act.

By updating its guidance shortly after the FATF Plenary, the Danish regulator signals that licensed operators are expected to incorporate the latest international risk classifications into their compliance procedures.

Kuwait and Papua New Guinea Added to the Grey List

The most significant change concerns the Grey List, which identifies jurisdictions under increased monitoring. According to the updated guidance, Kuwait and Papua New Guinea have been added to this list. Countries on the Grey List have committed to addressing identified strategic deficiencies within agreed timeframes.

The full list of jurisdictions currently subject to increased monitoring includes Algeria, Angola, Bolivia, Bulgaria, Cameroon, Ivory Coast, Democratic Republic of the Congo, Haiti, Kenya, Kuwait, Laos, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, the British Virgin Islands, and Yemen.

For gambling operators, the presence of a jurisdiction on this list represents a relevant risk indicator. Players with connections to these countries may require closer scrutiny as part of an operator’s internal risk-based approach.

Black List Remains Unchanged

The FATF Black List, which identifies jurisdictions subject to a call for countermeasures to protect the international financial system, remains unchanged following the February Plenary.

The jurisdictions currently on the Black List are the Democratic People’s Republic of Korea, Iran, and Myanmar. These countries are considered to present the highest level of risk under the FATF framework.

Although the Danish Gambling Authority’s update does not introduce new Black List entries, operators must continue to treat these jurisdictions as posing significant compliance risks within their anti-money laundering controls.

Enhanced Customer Due Diligence Under the Danish AML Act

Under Section 17(1) of the Danish Anti-Money Laundering Act, gambling operators are required to carry out Enhanced Customer Due Diligence when a player is assessed as posing a high risk of money laundering or terrorist financing.

The Danish Gambling Authority clarified that inclusion on a FATF list does not automatically trigger a legal obligation to apply Enhanced Customer Due Diligence. Instead, FATF classification must be treated as a significant risk factor within the operator’s broader risk assessment framework.

This means that operators must evaluate the individual circumstances of each customer. A connection to a Grey List jurisdiction increases the risk profile but does not in itself mandate enhanced measures in every case.

By contrast, the situation differs when it comes to the EU Regulation of High-Risk Third Countries. Pursuant to Section 17(2) of the Danish AML Act, Enhanced Customer Due Diligence is a mandatory legal requirement for all customers from jurisdictions listed under that EU regulation.

The distinction is important for compliance teams. While FATF listings influence risk scoring and monitoring procedures, EU-listed jurisdictions create a direct and automatic legal obligation to apply enhanced checks.

Operational Impact for Licensed Gambling Platforms

For licensed operators in Denmark, the updated guidance requires adjustments to internal compliance documentation, risk matrices, and customer onboarding procedures where relevant. Systems used to flag high-risk jurisdictions must reflect the addition of Kuwait and Papua New Guinea to the Grey List.

Operators must also ensure that compliance staff understand the difference between risk indicators and mandatory legal triggers. Misinterpreting FATF listings as automatic Enhanced Customer Due Diligence requirements could lead to inconsistent application of controls, while failing to account for increased monitoring obligations could expose an operator to regulatory risk.

Given that the FATF lists are periodically revised, the Danish Gambling Authority’s update underscores the need for continuous monitoring of international AML developments and timely implementation within licensed gambling businesses.

Our Assessment

The Danish Gambling Authority’s March 2026 update formally integrates the latest FATF decisions into national AML guidance for gambling operators. The addition of Kuwait and Papua New Guinea to the Grey List expands the range of jurisdictions that must be considered elevated risk factors in customer assessments. At the same time, the unchanged Black List maintains existing high-risk classifications. The clarification that FATF listing does not automatically require Enhanced Customer Due Diligence, while EU-listed jurisdictions do, defines the practical compliance obligations for Danish-licensed gambling operators under the current AML framework.