An analysis on developing the digital infrastructure and strengthening the “Know Your Customer”-procedures

Published 04-05-2021

On 27 march 2019, Danish parliament reached a political agreement on strengthening the Danish efforts against financial crime. As a part of this agreement, the Danish Financial Supervisory Authority (DFSA) was assigned to analyse and identify initiatives that can support companies, who are subject to AML/CFT regulations in their efforts against financial crime with a specific focus on strengthening their Know Your Customer (KYC) procedures.

Project AML/TEK is the result of this assignment. The project analyses seven initiatives with the goal of facilitating a more efficient use of technology, thereby strengthening the first line of defence, particularly through an increased use of the existing digital infrastructure in Denmark. The initiatives touches on various areas, as for example broader use of electronic identity solutions, the establishment of a public PEP-solution, and the possibility of allowing banks to share risk flags. Thus, the initiatives generally reflect the highly digitised nature of the Danish society, but are to a varying degree also applicable to other European countries and could serve as an inspiration towards better, more automated processes and a higher harmonisation of KYC procedures in the EU

The report does not present fully developed initiatives, but rather seeks to provide a clear baseline, which can facilitate an informed political decision on the next step of the efforts against ML/TF. A central part of the analysis is therefore a close look at the trade-off between the value of the specific initiatives and the legal implications for the individual or the company, for the customers of the company as well as the legal basis for accessing and potentially sharing the data in question, which are universal questions. 

Project AML/TEK is currently subject to a public consultation and the DFSA hope to both further stimulate the discussion on this very important topic and to gain insights into the opinions of all interested parties. The DFSA therefore welcomes all questions, suggestion and opinions, and hope that you can find the time to share them with us.

All input must be sent by email to with a copy sent to or by mail to the Danish Financial Supervisory Authority, Århusgade 110, 2100 København Ø, Att.: Lars Navntoft Henningsen.

Last updated 04-05-2021


Jesper Christiansen
Phone:41 93 35 06