Update to the FATF’s list of high-risk jurisdictions

25, Nov 2022

Persons and undertakings, including gambling providers, are required to conduct enhanced customer due diligence (EDD) pursuant to art. 17(1) of the Danish AML act, if a player is assessed to impose a higher risk of the gambling provider to be misused for money laundering or terrorist financing purposes.

The gambling provider shall conduct this risk assessment based on, but not limited to, the risk factors listed in Annex 3 to the AML act which includes the FATF high risk country lists (the so called black list and grey list).

That a country is listed on one of the FATF’s high risk lists does not inherently require EDD to be conducted but to be considered as a risk factor, as opposed to players from jurisdictions listed in the EU Regulation of High Risk Third Country list pursuant to art. 17(2) of the AML act.

The Danish Gambling Authority draws attention to the fact that the FATF has updated its Grey List (jurisdictions under increased monitoring) and Black List (call for action). The lists are now as follows:

  • Jurisdictions listed on the Grey List: Albania, Barbados, Burkina Faso, Cambodia, Cayman Islands, DR Congo, , Gibraltar, Haiti, Jamaica, Jordan, Mali, Morocco, Mozambique, Panama, Philippines Senegal, South Sudan, Syria, Tanzania, Turkey, Uganda, The United Arab Emirates, Yemen
  • Jurisdictions listed on the Black List: DPRK, Iran and Myanmar