Danish AML Law for Accountants: Complete KYC and AML Guide
Since the Danish Anti-Money Laundering Act took effect, accountants have become central gatekeepers against money laundering and terrorist financing. Accountants are 'obligated entities' with specific duties to identify, assess, and report suspicious activities. Violations can result in fines up to DKK 5 million. Finanstilsynet found deficiencies in 73% of the 48 audit firms inspected in 2024.
Your five core obligations
Risk assessment of your own firm — a written assessment of which client types, services, and geographic areas pose the greatest risks. Customer Due Diligence (KYC) — identification and verification, beneficial owner identification, understanding the business relationship. Ongoing monitoring of transactions and patterns. Reporting obligation to SOIK via goaml.dk before suspicious transactions are completed. Training and documentation for all client-facing employees.
Practical KYC process in 8 steps
Step 1: Initial screening (CVR, industry, ownership). Step 2: Obtain identification from management and beneficial owners. Step 3: Verify ownership against CVR and Central Ownership Register. Step 4: PEP screening. Step 5: Sanctions screening against EU and UN lists. Step 6: Risk classification (low, medium, high). Step 7: Document the KYC process. Step 8: Schedule annual reassessment.
Sitenyx as AML compliance support
Automatic transaction monitoring identifies unusual patterns — sudden revenue changes, large cash movements, trades with counterparts in unusual jurisdictions. KPI monitoring flags when key figures deviate significantly from industry averages. Full traceability ensures all observations are documented with timestamps.
The 5 most common mistakes
Not updating risk assessments regularly. Superficial KYC — noting CVR number alone is not enough. Missing PEP screening, even for local politicians. Tipping off — informing clients about reports is criminal. No employee training on AML obligations.
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Conclusion
AML obligations are not optional for accountants — they are a central part of the profession's responsibility. With a structured approach, regular updates, and the right digital tools, compliance can be integrated naturally into daily practice.
Ofte stillede sporgsmol
What is the penalty for non-compliance?
Fines up to DKK 5 million for firms and personal criminal liability for the responsible partner. Finanstilsynet can also issue public reprimands and require corrective action plans.
Do I need to file a report for every unusual transaction?
No. You must report when you have a reasonable suspicion of money laundering or terrorist financing. Unusual transactions should be investigated further, but not every anomaly requires a report. Document your assessment in either case.
How often must KYC be updated?
At minimum annually, and whenever there are significant changes in the client's business — ownership changes, new industries, significant revenue shifts, or new geographical exposure.
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Complete guide to AML obligations for Danish accountants. KYC process, risk assessment, reporting obligations, and the 5 most common mistakes.
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