Denmark Strengthens Anti-Money Laundering Framework: Key Amendments to the AML Act

The Danish Anti-Money Laundering Act (AML Act) is set to undergo significant changes aimed at bolstering the country's defenses against financial crimes. A draft amendment bill, published by the Financial Supervisory Authority (Finanstilsynet) on 5 November 2025, proposes several key enhancements to the existing framework. These proposed amendments are expected to enter into force on 1 July 2026.

These changes primarily target money laundering, terrorist financing, and, with particular emphasis, the financing of weapons of mass destruction ("proliferation financing"). Furthermore, they aim to ensure better compliance with financial sanctions.

The proposed amendments are primarily driven by updated recommendations from the Financial Action Task Force ("FATF") and forthcoming EU legislation, including the new EU AML Package, comprising a new EU AML authority (AMLA), a directly applicable AML regulation, a revised AML directive and updated rules on the transfer of funds and crypto-assets.

The draft bill is part of Denmark's ongoing alignment with international AML standards.

Overview of Key Amendments

Set out below is an overview of the key proposed amendments and their main implications for businesses subject to the AML Act.

New Requirements Relating to Proliferation Financing and Financial Sanctions

The draft bill introduces an explicit requirement for obliged entities to identify and assess the risk of potential breaches, non-implementation or circumvention of rules on the financing of proliferation. This obligation will be added alongside the existing requirements relating to money laundering and terrorist financing.

In this context, a statutory definition of "proliferation financing" will be introduced. The definition covers the provision of funds or financial services related to the development, acquisition, transport or use of nuclear, chemical or biological weapons, as well as dual-use goods and technology used for non-legitimate purposes.

Expanded Risk Assessment Obligations

Obliged entities will be required to maintain adequate written policies, procedures, and internal controls to ensure compliance with applicable financial sanctions regimes. This includes compliance with Danish and EU sanctions, as well as the obligation to freeze funds pursuant to the AML Act.

Requirement for Independent Testing of AML Policies and Controls

The draft bill introduces a general requirement for entities which are not otherwise subject to a requirement to have an internal audit function, to ensure that their AML policies, procedures and controls are subject to independent testing.

Where an internal audit function does not exist, the testing may be carried out by an external expert, including legal advisers or other suitably qualified professionals.

For smaller undertakings the requirement may be met through review by an employee other than the one performing the control, while sole proprietorships without employees may rely on an external expert.

The purpose of the requirement is to ensure objective assessment of AML controls, regular evaluation in light of changing risks and regulatory developments, and improved documentation for supervisory purposes.

Clarification of the Danish Financial Supervisory Authority's Enforcement Framework

Basis for Supervisory Reactions

The draft bill clarifies that the Danish Financial Supervisory Authority's decisions following inspections will generally be based on the information and documentation available at the time the inspection is concluded.

As a main rule, material submitted after the inspection will not be taken into account when deciding whether to issue an order or reprimand. However, limited exceptions may apply in special circumstances where it is objectively justified (e.g. IT outages or temporary unavailability of key information during the inspection).

Publication of Enforcement Actions

The proposal also maintains strict requirements for prompt publication of supervisory reactions.

Consequences of Non-Compliance

Violation of the complex rules for preventing money laundering and terrorist financing can result in fines. Money laundering is when someone unjustifiably receives or obtains-for themselves or others-a share of financial gains or funds obtained through a criminal offense.

Money laundering also includes unjustifiably concealing, storing, transporting, assisting in the disposal of, or otherwise subsequently contributing to securing the financial gain or funds from a criminal offense.

Companies and individuals covered by the Money Laundering Act also have an interest in ensuring that the company is not misused to assist in criminal transactions. The strong efforts to combat money laundering place increasing demands on companies’ procedures and policies in this area.

We find that companies and individuals are not aware of the requirements of the Money Laundering Act - or, in the worst case, that they are not aware that they are covered by the Act.

Focus Advokater Assistance

Focus Advokater assists with all aspects of advice related to the Money Laundering Act. Such cases usually have a short time frame. We prioritise being thorough, fast, and effective.

Anti-Money laundering in relation to:

• Compliance and crisis management

Supervision has been tightened and there is a marked interest in combating the criminal misuse of Danish companies and the financial system for money laundering.

Table: Key Proposed Amendments to the Danish AML Act

The proposed amendments significantly expand the scope and depth of AML compliance obligations, particularly in relation to proliferation financing, sanctions compliance and internal governance.

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