New AML Register Rules for Danish Gambling Operators

As part of its continued efforts to enhance financial transparency and prevent illicit activities, Denmark has implemented a new set of compliance obligations specifically targeting gambling operators based in Denmark but providing services outside its national borders. Starting 1 July 2025, a new regulatory requirement will come into effect, obligating specific gambling operators to register with the Danish Gambling Authority’s Anti-Money Laundering (AML) Register. This obligation is outlined in Executive Order No. 239, dated 27 January 2025.

This article outlines the implications of the new registration requirement, the procedure for notification, and the broader legal context for affected operators. Given prior legal correspondence with certain parties involved, the tone and content of this article are strictly formal, fact-based, and constructed to minimize any risk of legal disputes.

Scope of the new AML registration requirement

The regulatory update specifically applies to gambling operators falling under section 1(1)(19) of the Danish Anti-Money Laundering Act. These are businesses established in Denmark that only offer gambling services in other EU or EEA countries, and do not provide gambling in Denmark under a license issued in accordance with the Danish Gambling Act.

In other words, if a company is domiciled in Denmark and operates gambling services directed solely at foreign markets within the European Union or the European Economic Area, it must now be registered in the Danish Gambling Authority’s AML Register.

Importantly, this obligation does not extend to operators licensed under the Danish Gambling Act. Businesses already authorized to provide gambling in Denmark are explicitly excluded from the scope of the new Executive Order and do not need to undertake additional AML registration under these new rules.

The legal basis: Executive Order no. 239

The foundation of this new requirement is Executive Order no. 239, which was issued on 27 January 2025. The executive order is a legally binding regulation enacted by the Danish Gambling Authority (DGA) pursuant to its oversight responsibilities under the broader AML and gambling legislative frameworks.

The purpose of the order is to ensure that the Danish Gambling Authority can monitor and assess the money laundering risks associated with gambling services operated from Denmark, even if those services are directed abroad. This is in line with international AML standards, particularly those outlined by the Financial Action Task Force (FATF) and the European Union’s AML Directives.

Registration deadlines and required procedures

When and how to notify the Danish Gambling Authority

All applicable gambling operators are required to notify the DGA via its official notification form. This form is accessible on the Authority’s website under the section titled “Prevention of money laundering.”

The completed form must be submitted electronically and accompanied by relevant documentation that supports the application. This could include information regarding the nature of the gambling services offered, the countries in which they are being provided, ownership structure, AML policies, and customer due diligence procedures.

The notification must be submitted within 14 calendar days of either:

• Obtaining a gambling license in another EU/EEA jurisdiction, or
• Commencing gambling operations in another EU or EEA country.

Failure to comply with this timeframe may constitute a breach of the AML framework and could result in regulatory scrutiny or enforcement actions.

Ongoing compliance and change notifications

Once registered, the gambling operator assumes ongoing compliance responsibilities. One of the key obligations is ensuring that all submitted and recorded information remains accurate and up to date.

If there are any changes to the information previously submitted — such as changes in licensing jurisdiction, ownership, key personnel, or scope of gambling activities — the operator must:

• Submit a change notification using the change form provided on the DGA’s website; and
• Do so within 14 calendar days of the change taking effect.

These changes must also be submitted electronically and supported by relevant documentation, as applicable. This ensures the AML Register remains an accurate and reliable regulatory tool for financial monitoring and enforcement.

Termination of registration

An operator’s registration in the AML Register will cease if the gambling company no longer conducts operations falling under section 1(1) of the Executive Order, and has formally notified the Danish Gambling Authority in accordance with section 1(4) of the same order.

To effect this, the operator must communicate the termination of activities through the appropriate channel, also available on the DGA’s website, and ensure that all cessation criteria are met. This process is essential to avoid ongoing regulatory obligations or potential fines for non-disclosure.

Strategic implications for gambling operators

This new requirement signals a significant regulatory shift for Danish-based gambling operators targeting international markets. While these operators may not conduct business within Denmark itself, the Danish Government is extending its AML oversight to all operators based on Danish territory, in line with the principle that legal domicile entails certain supervisory responsibilities.

As a result, gambling companies must reassess their internal AML compliance frameworks, legal reporting obligations, and cross-jurisdictional risks. This includes:

• Reviewing and updating internal procedures for AML compliance.
• Assigning specific staff or departments responsible for liaising with the DGA.
• Monitoring deadlines to ensure timely submissions of forms and documentation.

Seeking local legal advice to ensure full understanding of the Executive Order and its practical implications.

How this aligns with broader EU AML developments

The move by Denmark is part of a larger trend across the European Union to tighten AML regulations in the gambling sector. With the rise in cross-border gambling operations and the increasing role of digital platforms, regulators are emphasizing greater transparency and traceability of gambling funds and customer transactions.

Moreover, the European Commission has recently proposed a central AML Authority (AMLA) that could potentially coordinate cross-border compliance efforts. Denmark’s proactive stance in requiring registration of even outward-facing operators reflects this broader policy alignment.

Final considerations and legal caution

It is essential for affected operators to treat this regulation with due seriousness. The DGA has a history of diligent enforcement and cross-agency cooperation, and non-compliance could result in reputational damage, financial penalties, or even legal actions — especially if an operator is found to be knowingly circumventing registration requirements.

At the same time, the Authority has made it clear that these measures are aimed at ensuring transparency, not penalizing operators unnecessarily. Businesses that engage constructively with the new framework and maintain robust internal compliance programs should face minimal difficulty in adapting.

Given prior legal contact and the potential sensitivity surrounding public discussion of these regulatory obligations, this article has been structured purely to inform and clarify the requirements imposed by Danish law, without casting any judgment or making unfounded assertions about any individual entity or operator.

FAQs

Who must register under the new Danish AML rules?
Danish-based gambling operators that offer services exclusively in other EU or EEA countries, and are not licensed under the Danish Gambling Act.

When do the new AML requirements take effect?
The registration obligation comes into force on 1 July 2025.

Are operators licensed in Denmark affected by this order?
No. Operators licensed under the Danish Gambling Act are not required to register under Executive Order no. 239.

Where can the notification form be found?
The form is available on the Danish Gambling Authority’s website under the section “Prevention of money laundering.”

What is the deadline for notification?
Notification must be submitted within 14 days of obtaining a license or starting gambling operations in another EU/EEA country.

How should operators report changes?
Changes must be reported within 14 days using the change form, also available on the DGA’s website.

What happens if an operator stops offering gambling abroad?
The registration can be terminated by notifying the DGA in accordance with section 1(4) of the Executive Order.

Does this apply to non-EU/EEA operations?
No. The regulation only covers gambling operations directed at other EU and EEA countries.

What documents must be submitted with the notification?
Documentation may include licenses, company structure, AML policies, and operational details.

What are the consequences of non-compliance?
Non-compliance may lead to regulatory investigations, fines, or reputational risks.