Date: 27.06.2025

by Sebastian Warowny

FATF Releases Updated List of High-Risk Jurisdictions for AML Compliance

The Financial Action Task Force (FATF) has updated its lists of high-risk jurisdictions relevant to anti-money laundering (AML) efforts. The Danish Gambling Authority has reminded licensed operators that these lists must be taken into account when assessing the risk profiles of players, in accordance with national AML regulations.

Updated FATF Lists

In June 2025, the Financial Action Task Force (FATF) revised its classification of jurisdictions under scrutiny for weak anti-money laundering frameworks. The changes affect two categories: the so-called Grey List, which includes jurisdictions under increased monitoring, and the Black List, which calls for intensified countermeasures.

The Danish Gambling Authority has reminded licensed operators that these lists must be incorporated into ongoing risk assessments of players. While their presence on FATF’s Grey or Black Lists does not automatically trigger enhanced due diligence (EDD), these designations are recognized as high-risk factors under Danish AML rules.

Grey and Black List Jurisdictions

The latest FATF Grey List includes a broad range of countries across several continents, such as Algeria, Nigeria, Vietnam, Bulgaria, and the Virgin Islands (British). The Black List remains limited to three jurisdictions: North Korea, Iran, and Myanmar.

Operators are expected to take these classifications into account when evaluating potential risks posed by customers, especially those who might be using gambling platforms to obscure illicit funds or engage in other forms of financial crime.

Under section 17(1) of Denmark’s AML Act, gambling operators are obligated to apply enhanced due diligence measures if a player is deemed to pose a heightened risk of involvement in money laundering or terrorist financing. The presence of a player’s country on FATF’s risk lists is one of several indicators used to assess such risk, as outlined in Annex 3 of the Danish AML Act.

However, FATF designation alone does not automatically mandate EDD. A higher threshold exists under section 17(2), which requires enhanced scrutiny only for jurisdictions listed in the European Union’s official High-Risk Third Country list.