The Danish Gambling Authority has drawn operators’ attention to the Financial Action Task Force’s updated lists of jurisdictions considered to present elevated money laundering and terrorist financing risks.
The update covers the FATF’s “grey list”, formally known as jurisdictions under increased monitoring, and its “black list”, which identifies jurisdictions subject to a call for action.
Gambling operators are expected to take both lists into account when assessing the money laundering and terrorist financing risk associated with individual players.
The grey list currently includes Angola, Bolivia, Bosnia and Herzegovina, Bulgaria, Burkina Faso, Cameroon, Côte d’Ivoire, the Democratic Republic of the Congo, Haiti, Iraq, Kenya, Laos, Lebanon, Monaco, Mozambique, Nepal, Nigeria, South Africa, South Sudan, Syria, Venezuela, Vietnam, the Virgin Islands and Yemen.
The black list includes the Democratic People’s Republic of Korea, Iran and Myanmar.
Under Section 17(1) of Denmark’s Anti-Money Laundering Act, gambling operators must apply enhanced customer due diligence where a player is assessed as posing a higher risk that the business could be misused for money laundering or terrorist financing.
FATF-listed jurisdictions are among the high-risk factors set out in Annex 3 of the legislation and should therefore inform an operator’s overall assessment.
However, the authority stressed that inclusion on a FATF list does not automatically trigger enhanced due diligence. Operators must consider the relevant circumstances and determine whether a player presents a higher risk.
Mandatory enhanced due diligence applies under Section 17(2) when a player is linked to a jurisdiction included on the European Union’s separate list of high-risk third countries.
The distinction means FATF designations remain an important risk indicator, but do not alone create an automatic EDD obligation under Danish rules.
The update comes amid continued international scrutiny of anti-money laundering frameworks across the gambling sector, with FATF recently reaffirming high-risk designations for Iran, North Korea and Myanmar, and separate concerns raised over illegal online gambling risks in jurisdictions such as Eswatini.
The FATF grey list identifies jurisdictions working with the organisation to address strategic AML and counter-terrorist financing deficiencies, while the black list covers jurisdictions subject to a call for action
