Compliance Updates
Spillemyndigheden Calls Attention to FATF’s Updated Lists of High-risk Jurisdictions

The Danish Gambling Authority has called attention to FATF’s (Financial Action Task Force) updated lists of high-risk jurisdictions: the Grey List (jurisdictions under increased monitoring) and Black List (call for actions). Among other things, gambling operators must include FATF’s lists of high-risk jurisdictions when assessing players’ risk.
Jurisdictions listed on the Grey List are Bulgaria, Burkina Faso, Cameroon, Croatia, DR Congo, Haiti, Kenya, Mali, Monaco, Mozambique, Namibia, Nigeria, the Philippines, Senegal, South Africa, South Sudan, Syria, Tanzania, Venezuela, Vietnam and Yemen.
Jurisdictions listed on the Black List are the Democratic People’s Republic of Korea, Iran and Myanmar.
Gambling operators are required to conduct enhanced customer due diligence (EDD) pursuant to section 17(1) of the Danish AML Act, if a player is assessed to impose a higher risk of the gambling operator being misused for money laundering or terrorist financing.
Gambling operators shall conduct this risk assessment based on Annex 3 to the AML Act (high-risk factors) which includes the FATF high-risk country lists (the so called black list and grey list).
It is not required that gambling operators perform EDD if a country is listed on the FATF’s list. EDD are only a requirement for players from jurisdictions listed in the EU Regulation of High Risk Third Country list pursuant to 17(2) of the AML Act.
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