Denmark's Financial Supervisory Authority has published revised guidance for banks and other entities subject to the Danish Anti-Money Laundering Act on assessing associations for money laundering and terrorist financing risk, replacing its 2022 guidance. The revision follows discussions between representatives of associations, the banking sector and relevant public authorities, and is intended to support risk-based customer due diligence that reflects an association’s actual risk profile. The guidance clarifies that, in certain cases, firms may limit the collection of identity information to board members who are authorised signatories, rather than obtaining information on the entire board. It also states that MitID can, as a rule, be used as the sole identity check for board members in low- and medium-risk associations. The revised guidance is positioned as part of a government initiative focused on the association sector, and the supervisor has also published related questions and answers on its website.
Danish Finanstilsynet 2025-09-02
Denmark's Financial Supervisory Authority revises guidance on AML risk assessments and customer due diligence for associations
Denmark's Financial Supervisory Authority has updated its 2022 guidance under the Danish Anti-Money Laundering Act for banks and entities on assessing associations' money laundering and terrorist financing risks. The guidance supports risk-based customer due diligence, focusing identity checks on authorised signatories and using MitID for low- and medium-risk associations. This revision is part of a broader government initiative targeting the association sector.