



Sanctions:
As a member of the EU, the country is party to all EU Sanctions
as well as UN sanctions.
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Offshore Jurisdiction Blacklists:
Information unavailable.
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US State Department Money Laundering Report - 2011
Denmark is not a major financial center, and although authorities
do not believe Denmark is often viewed as a particularly attractive
place for money laundering, there have been some instances of
placement of criminal proceeds in banks in situations where
neither the victim nor the perpetrator resided in Denmark. Major
sources for proceeds are drug trafficking and economic crimes,
particularly VAT and investment frauds, smuggling of goods, and
violations of intellectual property rights. Outlaw motorcycle gangs
have been involved in a range of offenses, including narcotics-
related offenses, smuggling of goods, and various financial
crimes. Denmark is geographically vulnerable to serving as a
transit country for smuggling into Sweden and Norway. The
proceeds of crime are typically transferred out of Denmark soon
after offenses occur.
DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO
CRIMINALIZATION OF MONEY LAUNDERING:
“All serious crimes” approach or “list” approach to predicate
crimes: All crimes
Legal persons covered: criminally: YES civilly: YES
CRIMINALIZATION OF TERRORIST FINANCING:
Ability to freeze terrorist assets without delay: YES
UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES
(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)
KNOW-YOUR-CUSTOMER RULES:
Covered entities: Banks and electronic money institutions, and
currency exchanges; insurance brokers and intermediaries;
pension and mutual funds; securities brokers and dealers;
safekeeping, portfolio, asset and capital managers; financial
leasing and factoring entities; issuers and processors of credit
cards, traveler’s checks, and money orders; accountants and
auditors; real estate agents; trust and company service providers;
attorneys; real estate agents; and casinos
Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES
SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:
Covered entities: Banks and electronic money institutions, and
currency exchanges; insurance brokers and intermediaries;
pension and mutual funds; securities brokers and dealers;
safekeeping, portfolio, asset and capital managers; financial
leasing and factoring entities; issuers and processors of credit
cards, traveler’s checks, and money orders; accountants and
auditors; real estate agents; trust and company service providers;
attorneys; real estate agents; and casinos
Number of STRs received and time frame: 2,095 in 2009
Number of CTRs received and time frame: Not applicable
MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:
Prosecutions: 306 in 2009
Convictions: 158 in 2009
Assets forfeited: criminally: approximately $41 million in 2009
civilly: Not available
RECORDS EXCHANGE MECHANISM:
With U.S.: YES
With other governments/jurisdictions: YES
Denmark is a member of the Financial Action Task Force (FATF).
Its most recent Mutual Evaluation Report can be found here: http:
//www.fatf-gafi.org/dataoecd/1/26/37588381.pdf
ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:
The Government of Denmark has a comprehensive anti-money
laundering/counter-terrorist financing (AML/CFT) regime and
should continue to enhance its laws and regulations as necessary
to adhere to international standards. Denmark should extend its
AML/CFT requirements to cover gaming establishments and
Internet gaming providers.
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US State Dept Narcotics Report 2011 (introduction):
No report available
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US State Dept Trafficking in Persons Report 2011
(introduction):
(Tier 1)
Denmark is primarily a destination and transit country for women
and children from Nigeria, Eastern and Central Europe, the Baltic
countries, Thailand, Southeast Asia, and South America
subjected to sex trafficking. The government did not report any
cases of forced labor in 2010, though authorities reported that the
agriculture sector in Denmark may include elements of forced
labor and highlighted that workers in domestic service,
restaurants, hotels, and factories may also be vulnerable to
forced labor. There were unconfirmed reports of foreign children
being forced to engage in organized street crime. As a result of a
2010 inquiry, the government concluded that au pair
organizations in Denmark were not being used as front
companies for human trafficking; however, the report also noted
that au pairs in the region are vulnerable to trafficking or other
forms of exploitation, and recommended the creation of a non-
profit recruitment organization to safeguard their rights. According
to NGO experts, the majority of au pairs in Denmark come from
the Philippines. According to NGOs, there has been a significant
increase in women from Africa engaged in prostitution in
Denmark, most of whom are controlled by pimps. According to
local observers, these women are highly vulnerable to trafficking.
The hundreds of unaccompanied foreign children who arrive in
Denmark every year are also vulnerable to human trafficking.
According to a 2010 ECPAT report, NGOs and police believe
there are trafficked children in Denmark who remain undetected,
as their traffickers keep them under close watch and are less
likely to exploit them in street prostitution.
The Government of Denmark fully complies with the minimum
standards for the elimination of trafficking. During the reporting
period, the government successfully prosecuted its largest sex
trafficking case to date, and it strengthened the severity of some
of the sentences imposed on traffickers in 2010. However, the
government’s emphasis on returning most foreign trafficking
victims to their countries of origin may provide a disincentive for
victims to cooperate with law enforcement and places victims at
risk of retribution and hardship upon their return. While the
government reported the possibility for trafficking victims to obtain
long-term residency in Denmark via asylum, on humanitarian
grounds, or in cases of family reunification, few trafficking victims
are actually provided with such alternatives prior to their removal
from Denmark.
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US State Dept Terrorism Report 2010
Overview: Denmark has developed both short-term and long-term
counterterrorism strategies. In the short term, terrorist networks
and groups were constantly monitored through intelligence,
police, and military efforts. In the long term, Denmark focused on
factors that counter radicalization and recruitment to terrorism,
including integration, anti-discrimination, active citizenship,
democratization, protection of human rights, conflict prevention,
and focused development assistance.
Since the re-printing of the cartoons of the Prophet Mohammed in
February 2008 by newspapers across Europe, Denmark and
Danish interests have been considered high-priority terrorist
targets among violent extremists. There were new indications that
terrorist groups abroad conspired to send terrorists to Denmark to
carry out terrorist attacks. Statements from al-Qa'ida members
and related groups underlined their continued focus on Denmark.
2010 Terrorist Incidents: There were at least three attempted
terrorist attacks in 2010. In January, an individual sought to attack
Danish cartoonist Kurt Westergaard in his residence. The
perpetrator was arrested before he could harm Westergaard and
was charged with attempt to commit a terrorist act. In September,
an individual prematurely detonated a bomb at the Hotel
Joergensen in Copenhagen, injuring himself. The bomb was
possibly meant for Jyllands-Posten, the newspaper that originally
commissioned and published the cartoons. In December, police in
Copenhagen and Stockholm arrested five individuals for
conspiring to commit acts of terrorism. The target was also
thought to be Jyllands-Posten.
Legislation and Law Enforcement: Two Danish agencies were
most involved in countering terrorist threats in Denmark: the
Danish Security and Intelligence Service (PET) and the Danish
Defense Intelligence Service (FE). PET and FE maintained a close
and collaborative relationship. This relationship was deepened
through the establishment of the Center for Terror Analysis (CTA).
CTA provided strategic and tactical support in the form of
systemically prepared assessments of terrorist threats against
Denmark.
In March, the Copenhagen City Court ruled in a case involving
terrorist financing, sentencing an individual to six-months in prison
for attempting to provide financial support to terrorist groups such
as the Revolutionary Armed Forces of Columbia and the Popular
Front for the Liberation of Palestine.
Countering Terrorist Finance: In January, PET published a
pamphlet in conjunction with the Professional Association for
Fundraising Organization entitled "Your Contributions Can Be
Misused," as part of its work in preventing terrorist financing.
Based on recommendations identified in the Financial Action Task
Force Mutual Evaluation of June 2006, Denmark has made
significant advances with respect to Anti-Money Laundering and
Combating the Financing of Terrorism (AML/CTF). Because of its
close cooperation with Greenland and the Faroe Islands, over
which it has sovereignty, Denmark has sufficiently implemented
the Financial Action Task Force recommendations in order to be
considered for removal from the regular follow-up process, with a
view to only submitting biennial updates. However, Denmark
needs further development in areas such as incorporating
Greenland and the Faroe Islands in legislation with respect to
AML/CTF.
Regional and International Cooperation: The Danish government
continued to cooperate with international organizations,
particularly within the UN framework and through the EU.
Countering Radicalization and Violent Extremism: In order to
understand the dynamics behind terrorism and become more
effective in countering it, the Danish Institute for International
Studies (DIIS) has conducted research on the different aspects of
radicalization and the link with terrorism. As part of its 2010
budget, the Danish government allocated approximately US$ 1.8
million to DIIS for its continued research on terrorism.
The Danish government also supported the establishment of the
Center for Studies in Islamism and Radicalization (CIR) based in
the Political Science Department at Aarhus University. CIR
research has focused on three major topics: radicalization,
recruitment, and the international consequences of political Islam.
Because of efforts of Danish and foreign researchers, CIR
published four major research reports during 2010 on
radicalization and recruitment in Denmark, Italy, and England.
Development assistance was an important part of the overall
Danish effort against international terrorism and radicalization. In
April, the Danish government established a new US$ 25+ million
inter-ministerial stabilization fund to promote the coordination of
civil and military efforts. There was also a strong civil society
component to the Danish strategy. Groups such as the
International Humanitarian Service (IHB) contributed by sending
civilians to conflict and crisis areas to encourage peace and
stability. The IHB is a collection of civilians who are trained to
participate in international development projects that are
coordinated through the Danish Ministry of Foreign Affairs.
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Are there Sanctions in force against it? (UN/EU/US)
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Is it on FATF list of non-cooperative countries?
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Is it on OECD list of uncooperative Tax Havens?
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OECD - Implementation status of Tax Standard
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Is it on EU 'white' list of equivalent jurisdictions?
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Offshore Finance Center (Original IMF List)?
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Is it on the US Secretary of Treasury list of jurisdictions of Primary Money Laundering concern?
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Is it on the US Secretary of State list of jurisdictions identified to be supporters of International Terrorism?
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Is it on US Department of State International Narcotics Control Majors List?
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US Dept of State Money Laundering assessment (INCSR)
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Government Actions (For further info see INCRS below):
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- Criminalized Drug Money Laundering?
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- Criminalized Beyond Drugs?
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- Record Large Transactions?
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- Maintain Records Over Time?
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- Report Suspicious Transactions?(NMP)?
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- Egmont Financial Intelligence Units?
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- System for Identifying/Forfeiting Assets?
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- Arrangements for Asset Sharing?
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- Cooperates with International Law Enforcement?
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- International Transportation of Currency?
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- Ability to Freeze Terrorist Assets w/o Delay?
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- Disclosure Protection "Safe Harbor"?
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- Criminalized Financing of Terrorism?
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- States Party to 1988 UN Convention?
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- International Terrorism Financing Convention?
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Corruption (Transparency International)
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Ease of doing business (World Bank)
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FATF 40 + 9 recommendations
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Mutual Evaluation Report: 2006
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C - Fully Compliant , L - Largely Compliant, P - Partially Compliant N - Non-Compliant
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1. Money Laundering Offence
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14. Protection & no tipping-off
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2. ML offence – mental element and corporate liability
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15. Internal controls, compliance & audit
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3. Confiscation and provisional measures
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4. Secrecy laws consistent with the Recommendations
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5. Customer due diligence
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6. Politically exposed persons
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19. Other forms of reporting
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20. Other NFBP & secure transaction techniques
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8. New technologies & non face-to-face business
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21. Special attention for higher risk countries
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9. Third parties and introducers
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22. Foreign branches & subsidiaries
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23. Regulation, supervision and monitoring
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24. DNFBP - regulation, supervision and monitoring
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12. Designated Non-Financial Businesses and Professions – R.5, 6, 8-11
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25. Guidelines & Feedback
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13. Suspicious transaction reporting
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Institutional and other measures
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31. National co-operation
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27. Law enforcement authorities
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28. Powers of competent authorities
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33. Legal persons – beneficial owners
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34. Legal arrangements – beneficial owners
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30. Resources, integrity and training
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International Co-operation
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38. MLA on confiscation and freezing
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36. Mutual legal assistance (MLA)
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40. Other forms of co-operation
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Nine Special Recommendations
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SR.I Implement UN instruments
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SR VI AML requirements for money/value transfer services
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SR.II Criminalise terrorist financing
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SR VII Wire transfer rules
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SR.III Freeze and confiscate terrorist assets
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SR.VIII Non profit organisations
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SR.IV Suspicious transaction reporting
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SR.IX Cross Border Declaration & Disclosure
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SR.V International co-operation
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* In October 2010, The FATF recognized that Denmark had made
significant progress in implementing the 49 recommendations and that
from that date it should report on a biennial basis on the actions it will
take in the AML/CFT area.
Please also note that any risk assessment should take into
consideration all follow-up reports.
- Know Your Customer Provisions
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- Criminalized Tipping Off?
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- Report Suspected Terrorist Financing?
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- State Party to United Nations TOC?
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- State Party to United Nations CAC?
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________________________________________________________
AML News / Updates
February 10, 2011 - The Global Forum on Transparency and
Exchange of Information for Tax Purposes has issued a Combined
phase 1 & phase 2 peer review for Denmark
View Review....
November 3, 2010 - FATF has agreed that Denmark has taken
sufficient action to address aml issues in previous mutual evaluations
and has therefore been taken off the regular follow-up process.
Read More.......
Links:
Worldwide AML Legislation (International Bar Association)
Local AML News / Sanctions
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Last Updated: 16 April 2012
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