Adopted AML bill adds sanctions controls and independent testing

Businesses and persons covered by Denmark’s anti-money-laundering legislation face express requirements for written financial-sanctions controls under bill L 9, adopted by Folketing on 3 September 2026Retsinformation. The adopted text specifies a general commencement date of 15 September 2026Retsinformation and adds requirements concerning proliferation-financing riskRetsinformation and independent testing of policies, procedures and controlsRetsinformation.

The amendment to section 7 brings into the risk assessment potential breaches, non-implementation or circumvention of obligations concerning proliferation financing. The new statutory definition concerns supplying funds or financial services for activities involving nuclear, chemical or biological weapons used for illegitimate purposes contrary to national law or international obligations. It encompasses activities such as manufacture, acquisition, development, export, transfer and use.

Under the amended section 8, covered businesses and persons must have adequate written policies, procedures and controls addressing compliance with financial-sanctions legislation and regulations and the specified section 34 a provision.Retsinformation Controls concerning proliferation financing must additionally reflect the section 7 risk assessment and take account of the business’s size.

The independent-testing requirement is extended to businesses and persons outside the existing first sentence of section 8(4)Retsinformation, excluding their branches, distributors and agents in Denmark. They must ensure testing by an independent audit function.Retsinformation Where no such function exists, an external expert may perform the test.Retsinformation The text therefore expressly provides an alternative for organisations without their own independent audit function.

Separate amendments introduce half-yearly publication of previously published but still unfulfilled supervisory orders under the digital operational resilience framework. Companies with orders appearing on the relevant overview must place a visible link on their website’s front page. These publication provisions apply only to orders issued after commencement, and allow specified exceptions for IT-security concerns or financial stability.

The adopted text contains other financial-sector and criminal-law changes, with a later commencement date for two specified consumer-credit amendments. The legislative basis for the controls covered here is bill L 9 of 3 September 2026, section 1’s amendments to hvidvaskloven sections 4 a, 7 and 8, the supervisory-publication provisions and section 20.