Denmark Updates AML Act: New Audits and Proliferation Risk Requirements for Gambling Operators

Effective 15 September 2026, licensed gambling operators in Denmark face new obligations under the amended Anti-Money Laundering (AML) Act. These changes, adopted by the Danish Parliament on 3 September 2026, bring Denmark in closer alignment with the Financial Action Task Force (FATF) recommendations regarding money laundering and combating the financing of terrorism and proliferation.

The Core Amendments: Impact on AML Compliance in Denmark

The revised AML Act mandates that all gambling operators prepare thorough risk assessments addressing the financing of proliferation. Operators must also have documented policies, procedures, and controls not only for anti-money laundering and terrorism financing but also specifically to manage risks related to proliferation financing and to comply with financial sanctions targeting certain jurisdictions, individuals, and companies.

Risk Assessments for Proliferation Financing

As of 15 September 2026, the requirements for gambling operators expand to cover:

• Formal risk assessments of exposure to proliferation financing risks
• Documentation and regular review of these assessments
• Integration of findings into broader AML and counter-terrorism policies

The inclusion of proliferation risk aligns Denmark with FATF’s evolving focus on the intersection of financial crime and international security threats. Operators must incorporate proliferation financing into their existing risk-based approach, updating both the scope and the rigor of their compliance frameworks.

Written Policies, Procedures, and Controls

The Act obligates gambling operators to develop and maintain up-to-date, written policies and operational procedures covering:

• Prevention of money laundering
• Combating the financing of terrorism
• Specific measures to address financing of proliferation
• Procedures to comply with financial sanctions regimes applicable to jurisdictions, persons, and entities

Documentation must explicitly address each risk area. This written framework becomes integral to ongoing compliance, forming the basis for staff training and internal monitoring.

Introduction of an Independent Audit Function

In a significant shift, the amended Danish AML Act requires the establishment of an independent audit function to review the effectiveness of an operator’s policies, procedures, and controls. This audit obligation covers the full range of AML, counter-terrorism, and anti-proliferation measures, as well as compliance with financial sanctions.

The audit function must operate independently from general management. Operators may appoint a third-party auditor, or in larger organizations, staff from outside the compliance and operational teams. The auditor’s findings should be duly documented and available for inspection by the Danish Gambling Authority (Spillemyndigheden) and, when relevant, other regulators concerned with AML compliance.

"The purpose of the amendments is to strengthen Denmark’s compliance with the FATF’s recommendations on combating money laundering and the financing of terrorism and proliferation." — Danish Parliament legislative summary

Entry into Force and Regulatory Oversight

All new requirements come into effect on 15 September 2026, with the full text of the legislation published by the Danish Parliament. The Danish Gambling Authority will be responsible for monitoring operators’ adherence to the new obligations. Noncompliance may result in regulatory action, ranging from warnings to financial penalties or licence review.

Context: Denmark’s AML Landscape and International Standards

Denmark’s legislative update follows a sustained push by the FATF to have member countries close gaps that allow financial systems to be exploited for proliferation financing. Danish regulators have referenced the need to harmonise national legal frameworks with FATF’s most recent recommendations, particularly as cross-border payments and digital gambling raise risks of abuse for illicit financial purposes.

These amendments apply to all operators holding Danish licences, both online and land-based, and are designed to reinforce the resilience of Denmark’s gambling sector against emerging threats in line with other European markets’ enhancements to AML supervision.

Operator Actions and Next Steps

Operators must review and, if needed, update their risk assessments to address proliferation financing by the September deadline. Documented policies should clearly reference the new obligations, and the process for commissioning and reporting on independent audits must be in place. Internal training materials and compliance checklists also require updates to reflect the broadened scope of Danish AML regulation.

Clear communication with the Danish Gambling Authority is encouraged to ensure interpretations and implementation meet both the letter and intent of the revised Act. Operators should also follow updates on regulation as other jurisdictions may adopt similar requirements in response to FATF evaluations.