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

07, Mar 2024

The Danish Gambling Authority calls 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 risk assessing players. 

Jurisdictions listed on the Grey List: 

  • Bulgaria, Burkina Faso, Cameroon, Croatia, DR Congo, Haiti, Jamaica, Kenya, Mali, Mozambique, Namibia, Nigeria, Philippines, Senegal, South Africa, South Sudan, Syria, Tanzania, Türkiye, Vietnam, Yemen

Jurisdictions listed on the Black List: 

  • Democratic People’s Republic of Korea, Iran and Myanmar

Persons and undertakings, including 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. 

The gambling operator 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 list 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. 17(2) of the AML Act.