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Denmark expands AML duties for gambling operators

From 15 September, gambling operators must assess proliferation-financing risks, strengthen sanctions controls and introduce independent testing of their compliance frameworks.

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Denmark
Key Points
Denmark’s amended Anti-Money Laundering Act takes effect on 15 September
Gambling operators must assess proliferation-financing risks and maintain written controls
Independent audit functions or external experts must test the measures

Denmark has adopted amendments to its Anti-Money Laundering Act that will broaden compliance duties for gambling operators from 15 September 2026.

The Folketing (Danish Parliament) passed the legislation at its third reading on 3 September as part of a wider package affecting financial and payment-sector laws.

The changes are intended to strengthen Denmark’s implementation of Financial Action Task Force recommendations covering money laundering, terrorist financing and the financing of weapons proliferation.

The legislation adds a statutory definition of proliferation financing, covering funds or financial services connected with nuclear, chemical or biological weapons used for illegitimate purposes.

Gambling operators will be required to assess their exposure to potential breaches, failures to implement or circumvention of proliferation-financing obligations. Existing risk assessments must therefore be expanded beyond money laundering and terrorist financing to consider relevant restrictions involving countries, individuals, groups, legal entities and other bodies.

Operators must also maintain adequate written policies, procedures and controls addressing compliance with both proliferation-financing rules and wider financial sanctions. The proliferation-financing measures must be based on the operator’s risk assessment and proportionate to the size of the business.

The amendments additionally require an independent audit function to test the relevant policies, procedures and controls. Where an operator does not have such a function, the legislation allows the testing to be conducted by an external expert.

The amendments follow Denmark’s July gambling figures, which showed GGR rising 17.2% year-on-year to DKK760m ($119.2m), led by online casino and betting growth.

The Danish Gambling Authority has also secured a court order blocking Polymarket and 98 other unlicensed websites, while accepting applications for land-based casino licences until 3 November.

Good to know

The legislation permits an external expert to conduct the required testing where an operator does not have an independent audit function

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