Denmark: Gambling Operators’ Obligation to Assess the Risk of New Technology Before Launch

According to Section 7(1) of the Anti‑Money Laundering Act, gambling operators are required to identify and assess the risk that they may be misused for money laundering. The risk assessment must be based on the operator’s business model and must cover risk factors associated with customers, products, services and transactions, as well as delivery channels and countries or geographical areas.

The Danish Gambling Authority points out that this obligation means that any new technology used by a gambling operator must be risk‑assessed before it is launched, ensuring that no part of the operator’s business remains unassessed. New technology could, for example, include the introduction of new games or new payment solutions. The introduction of new technology therefore constitutes a change to the operator’s business model, which requires an update of the risk assessment.

When launching a new game product or other technology with which the operator has no prior experience, the operator must investigate whether relevant sources exist that can support the risk assessment.

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