Operators reminded of enhanced due diligence duties as global AML risks evolve
FATF Updates Global Risk Lists for 2024
The Financial Action Task Force (FATF) has released its latest update to the global Anti-Money Laundering (AML) country risk lists, prompting regulatory agencies worldwide to reinforce compliance awareness. The FATF’s grey list now includes 26 jurisdictions flagged for strategic deficiencies in their AML frameworks. These include nations like South Africa, Nigeria, Lebanon, and Vietnam, all considered to require additional scrutiny by financial institutions and gaming operators alike.
The black list, designating countries with severe AML non-compliance and no ongoing cooperation with the FATF, remains short but serious: North Korea, Iran, and Myanmar. These countries are deemed high-risk and subject to international countermeasures.
Danish Gambling Authority Reacts to FATF Update
Following this release, the Danish Gambling Authority (Spillemyndigheden) has issued a compliance advisory to licensed operators. While Denmark’s AML regulations are not automatically tied to the FATF lists, the Authority reminded operators that enhanced customer due diligence (CDD) is required under the Danish AML Act if a player poses a higher-than-average risk of money laundering—regardless of their country of origin.
This advisory reinforces the principle that risk-based assessments remain central to AML compliance. It also clarifies that operators do not need to treat all individuals from FATF-listed countries as high-risk by default, but should consider other risk indicators such as payment behavior, transaction anomalies, and source of funds.
Broader AML Landscape: Global Progress and Local Focus
Interestingly, while FATF recently removed the Philippines from its grey list—citing progress by regulators like PAGCOR—other jurisdictions have seen their AML reputations further scrutinized. For gambling operators, this evolving landscape demands agility in risk management and KYC (Know Your Customer) procedures.
In Denmark, AML enforcement has become increasingly assertive. Earlier this year, the Danish Gambling Authority launched initiatives to clamp down on illegal gambling activities, especially on platforms like Twitch, where unlicensed gaming content can expose players to unregulated financial flows.
Market Context: Growth and Compliance
Despite these regulatory pressures, Denmark’s gambling sector remains healthy. In April, Spillemyndigheden reported a 5.6% rise in Gross Gaming Revenue (GGR) year-on-year, totaling DKK 11bn ($1.73bn) in 2024. With growth comes responsibility—operators must balance expansion with rigorous compliance frameworks, particularly as international AML standards continue to tighten.
Looking Ahead: Strengthening Resilience
As regulators like Spillemyndigheden intensify oversight and FATF updates continue to shape global risk perceptions, gambling operators must refine their compliance policies, staff training, and transaction monitoring tools. The message is clear: AML vigilance is no longer optional but a strategic necessity in an increasingly interconnected financial and gaming environment.
