Denmark, as an EU Member State, is subject to EU-level AML/CFT regulations that govern cryptocurrency and digital asset travel-rule requirements, with the Danish Financial Supervisory Authority (FSA) serving as the national competent authority for implementing and enforcing these rules. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Crypto-asset service providers in Denmark must comply with the EU's travel rule framework established under Regulation (EU) 2023/1113, which applies from 30 December 2024, requiring the collection and disclosure of information about senders and beneficiaries of crypto-asset transfers irrespective of value. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Denmark is transitioning from the previous registration regime for crypto-asset service providers to a single licensing regime under Regulation (EU) 2023/1114 (MiCA), with the 4AMLD registration requirements being removed for these categories. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The EU's new anti-money laundering framework, including the AMLA Regulation (EU) 2024/1620 and Directive (EU) 2024/1640, applies from 1 July 2025, with Directive (EU) 2015/849 being repealed and replaced by Directive (EU) 2024/1640 as of 9 July 2027. Authority for Anti-Money Laundering and Countering the Financing of Terrorism

The practical reality is that Danish crypto-asset businesses must implement the EU travel-rule requirements, including enhanced due diligence for self-hosted addresses and cross-border correspondent relationships, while awaiting full implementation of the new EU AML/CFT package. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The primary regulatory framework for cryptocurrency and digital asset travel-rule requirements in Denmark comes from EU-level legislation, including Directive (EU) 2015/849 (the 4th Anti-Money Laundering Directive, 4AMLD), which has been amended by Regulation (EU) 2023/1113 to include crypto-asset service providers within the definition of "financial institutions" under Article 3. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Regulation (EU) 2023/1113 creates a system for dealing with exchanges of crypto-assets to ensure they are not used illegally, such as to circumvent sanctions or to fund terrorism or war, requiring crypto-asset service providers to gather and disclose to authorities certain information about senders and beneficiaries of any transfers of these assets, irrespective of their value. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Regulation (EU) 2023/1114 (the markets in crypto-assets regulation, MiCA) defines additional categories of virtual asset service providers and establishes a single licensing regime, replacing the previous registration requirements under Article 47, paragraph 1 of Directive (EU) 2015/849. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The European Banking Authority (EBA) has been tasked since 1 January 2020 with preventing the use of the financial system for money laundering and terrorist financing purposes and leading, coordinating and monitoring the efforts of all EU financial services providers and competent authorities in this domain. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The EU's anti-money laundering rules are based on international standards adopted by the Financial Action Task Force (FATF), including the FATF recommendations from 2012, which were revised in 2023. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Regulation (EU) 2024/1620 establishes the Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), based in Frankfurt am Main, which applies from 1 July 2025 and has extensive regulatory and supervisory oversight and enforcement powers over obliged entities and national public authorities. Authority for Anti-Money Laundering and Countering the Financing of Terrorism

Directive (EU) 2024/1640, which amends and repeals Directive (EU) 2015/849, becomes applicable as of 9 July 2027, establishing new mechanisms for Member States to prevent the use of the financial system for money laundering or terrorist financing. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The EU legal framework operates under the Treaty on the Functioning of the European Union (TFEU), with Title VII covering approximation of laws for the internal market, including rules requiring financial and certain non-financial operators to identify clients, monitor transactions, and report suspicions to Financial Intelligence Units (FIUs). Money laundering - EUR-Lex

Directive (EU) 2018/843 (the Fifth Anti-Money Laundering Directive, 5AMLD) amended the 4AMLD and was part of the EU's evolving framework, with the changes introduced by amending Regulation (EU) 2023/1113 applying from 30 December 2024. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Denmark implements the EU AML/CFT directives through its national legislation, including the Danish Act on Measures to Prevent Money Laundering and Financing of Terrorism (the Danish AML Act), which transposes Directive (EU) 2015/849 as amended, and the Danish Financial Supervisory Authority (Finanstilsynet) is the designated competent authority responsible for supervising obliged entities including crypto-asset service providers. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Under Regulation (EU) 2023/1113, all categories of crypto-asset service providers as defined in Regulation (EU) 2023/1114 are included within the definition of "financial institutions" in Directive (EU) 2015/849, subjecting them to the full AML/CFT obligations framework. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Registration requirements have been removed in relation to those categories of crypto-asset service providers which will become subject to a single licensing regime under Regulation (EU) 2023/1114, per Article 47, paragraph 1 of Directive (EU) 2015/849 as amended. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The Danish Financial Supervisory Authority (Finanstilsynet) is the competent authority responsible for licensing and registration of crypto-asset service providers in Denmark, operating within the framework of the EU's MiCA regulation and the Danish AML Act. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Crypto-asset service providers must apply appropriate risk mitigating measures when establishing cross-border correspondent relationships involving the execution of crypto-asset services with a respondent entity not established in the EU, as required under new Article 19b of Directive (EU) 2015/849. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Member States may require crypto-asset service providers established in their territory in forms other than a branch, and whose head office is situated in another Member State, to appoint a central contact point in their territory, per Article 45, paragraph 9 of Directive (EU) 2015/849. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Denmark has had entities registered as virtual asset service providers under the previous registration regime, but the transition to the MiCA licensing regime under Regulation (EU) 2023/1114 is currently ongoing, with the single licensing framework replacing the earlier registration-based system. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

No specific number of licensed crypto-asset service providers in Denmark under MiCA has been publicly disclosed; however, the regulatory transition from registration to licensing is mandated by EU law and applies to all Danish crypto-asset businesses. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Capital requirements for crypto-asset service providers in Denmark are established under the MiCA regulation (Regulation (EU) 2023/1114), which sets the licensing framework and prudential requirements for all EU member states, including Denmark. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The application process for crypto-asset service provider licensing in Denmark is administered by Finanstilsynet, which evaluates applications for compliance with the EU AML/CFT framework and MiCA requirements. Authority for Anti-Money Laundering and Countering the Financing of Terrorism

AMLA may select, every three years, obliged entities which are credit and financial institutions with high-risk profiles and operations in at least six Member States for direct supervision, which could include Danish crypto-asset service providers meeting these criteria. Authority for Anti-Money Laundering and Countering the Financing of Terrorism

Crypto-asset service providers in Denmark must comply with customer due diligence (CDD) requirements under Directive (EU) 2015/849, including transparency rules regarding the identification of customers, especially beneficial owners of companies and legal arrangements such as trusts. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Enhanced customer due diligence (EDD) measures are required for situations of higher risk, such as trading with banks situated outside the EU and dealing with natural or legal entities established in non-EU countries identified by the Commission as high-risk third countries. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Crypto-asset service providers must require enhanced due diligence measures under Article 19a of Directive (EU) 2015/849, which mandates applying mitigating measures commensurate with the risks associated with transfers involving self-hosted addresses. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Under new Article 24a of Directive (EU) 2015/849, crypto-asset service providers must apply enhanced customer due diligence measures and appropriate risk mitigating measures when performing crypto-asset services with unregistered or unlicensed entities which provide crypto-asset services. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Suspicion of money laundering or terrorist financing must be reported to the public authorities, usually the Financial Intelligence Unit (FIU), which in Denmark is the Danish FIU operating under the State Prosecutor for Serious Economic and International Crime (SØIK). Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Information on beneficial ownership for companies must be held in each Member State in a central register, such as a commercial register, a company register or a public register, and Denmark maintains a central beneficial ownership register (Ejerregisteret) administered by the Danish Business Authority. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Obliged entities, including crypto-asset service providers, must introduce supporting measures such as ensuring the proper training of personnel and establishing appropriate internal preventive policies and procedures, as required under Directive (EU) 2015/849. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The directive prohibits banks from keeping anonymous safe-deposit boxes in addition to anonymous accounts and passbooks, and includes measures to prevent risks linked to prepaid cards and virtual currencies, including lowering the identification threshold for prepaid cardholders from €250 to €150. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The European Banking Authority is required to issue guidelines on risk variables and risk factors to be taken into account by crypto-asset service providers when entering into business relationships or carrying out transactions in crypto-assets, per Article 18 of Directive (EU) 2015/849. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Financial and certain non-financial operators must identify their clients (including beneficial owners of companies and trusts), monitor transactions and report any suspicions of money laundering to Financial Intelligence Units, and these obligations are governed by the TFEU framework. Money laundering - EUR-Lex

No specific enforcement actions, fines, or penalties imposed on Danish crypto-asset service providers by name have been publicly documented; however, the enforcement framework under which Danish authorities operate is established. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

AMLA can apply administrative monetary sanctions and periodic penalty payments to high-risk obliged entities under direct supervision, and the Court of Justice of the European Union has the power to review, annul, reduce or increase these sanctions. Authority for Anti-Money Laundering and Countering the Financing of Terrorism

The European Commission may inform the European Parliament and Council of any failures by Member States to correctly apply EU rules tackling money laundering and terrorism financing in Directive (EU) 2024/1640, which includes the obligation for Member States to ensure adequate enforcement mechanisms. Authority for Anti-Money Laundering and Countering the Financing of Terrorism

AMLA acts against supervisors failing in their duty and settles any cross-border problems between financial supervisors, ensuring that national supervisory authorities, including Denmark's Finanstilsynet, are held accountable for their enforcement obligations. Authority for Anti-Money Laundering and Countering the Financing of Terrorism

AMLA conducts peer reviews of non-financial supervisors and public bodies and assesses financial supervisors periodically to ensure consistently high-level standards and practices, which serves as an indirect enforcement mechanism for national authorities like those in Denmark. Authority for Anti-Money Laundering and Countering the Financing of Terrorism

The EU regulatory framework for crypto-assets under Regulation (EU) 2023/1114 addresses anti-money laundering and market conduct but does not establish harmonized tax treatment for virtual assets within the EU. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

No specific tax guidance for virtual assets in Denmark has been issued within the AML/CFT framework, which focuses exclusively on travel-rule requirements rather than tax matters. Authority for Anti-Money Laundering and Countering the Financing of Terrorism

A significant gap exists in the transitional period between the current registration regime for crypto-asset service providers under Directive (EU) 2015/849 and the new single licensing regime under Regulation (EU) 2023/1114 (MiCA), creating potential regulatory uncertainty for businesses operating in Denmark. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The repeal of Directive (EU) 2015/849 is scheduled for 9 July 2027, when it will be replaced by Directive (EU) 2024/1640, meaning Danish crypto-asset service providers must navigate two overlapping regulatory frameworks during this transitional period. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The travel-rule requirements under Regulation (EU) 2023/1113 require crypto-asset service providers to gather information about senders and beneficiaries for all transfers regardless of value, which may create operational burdens for businesses dealing with high volumes of small-value transfers. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Self-hosted addresses present particular challenges for Danish crypto-asset service providers, as they must apply risk mitigating measures commensurate with the risks associated with transfers involving these addresses, which require enhanced due diligence and sophisticated risk assessment capabilities. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Cross-border correspondent relationships involving crypto-asset services with entities not established in the EU require appropriate risk mitigating measures, and the EBA is tasked with issuing guidelines including minimum action to be taken where a respondent entity is not registered or licensed, creating compliance complexity for Danish firms engaged in international business. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Danish crypto-asset service providers may face risks related to operations in non-EU countries with inefficient AML/CTF regimes, as the EU maintains a list of "high-risk third countries" and requires enhanced due diligence for entities established in these jurisdictions. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

The practical implementation of the EU's new AML/CFT package, including AMLA's direct supervision of high-risk financial institutions with operations in at least six Member States, may create additional compliance burdens for larger Danish crypto-asset businesses. Authority for Anti-Money Laundering and Countering the Financing of Terrorism

The EU Commission conducts European-level risk assessments of money laundering and terrorist financing risks affecting the internal market, and Danish crypto-asset businesses must remain responsive to evolving risk profiles identified through these assessments. Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Greater international coordination is needed to address the cross-border nature of crypto-asset transfers, as the EU's travel-rule framework requires cooperation between FIUs across member states, but the effectiveness depends on third countries implementing comparable standards, especially given that EU financial crime rules are based on FATF recommendations. Money laundering - EUR-Lex

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Preventing abuse of the financial system for money laundering and terrorism purposes (until 2027)

Preventing money laundering by means of the financial system