New draft bill proposing amendments to the Danish Anti-Money Laundering Act

Background

On 5 November 2025, the Financial Supervisory Authority (Finanstilsynet) published a consultation draft of an amendment bill to the Anti-Money Laundering Act (the "AML Act"). The draft bill proposes a number of amendments to the AML Act, aimed at strengthening the framework for combating money laundering, terrorist financing and, in particular, the financing of weapons of mass destruction ("proliferation financing"), as well as enhancing 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.

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

Overview of key amendments

New requirements relating to proliferation financing and financial sanctions

Expanded risk assessment obligations

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.

Policies, procedures and controls covering financial sanctions

In addition, 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

Independent audit or external review

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.

Conclusion

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

Expected effective date

The proposed changes are scheduled to take effect on 1 Juli 2026. The draft bill is part of Denmark's ongoing alignment with international AML standards. Entities subject to the AML Act should begin assessing the impact of the proposed changes well in advance of the expected entry into force on 1 July 2026.

Want to know more?

For more information, please contact Plesner's teams for Banking and Finance. 

Read the draft bill here (in Danish).