Are commercial gaming operators classified as DNFBPs under UAE AML law?
Yes. Following the establishment of the UAE’s regulated commercial gaming sector, licensed gaming operators are brought within the AML/CFT regime as a designated category subject to the same preventive obligations that apply to other DNFBPs. They are supervised for AML purposes by the General Commercial Gaming Regulatory Authority, working within the national framework.
This classification means gaming operators must apply customer due diligence, screen customers, appoint a compliance officer, monitor transactions, file suspicious transaction reports, and keep records for at least five years. The national policy paper for the sector stresses a tailored, risk-based approach because gaming carries distinct vulnerabilities such as anonymous play, third-party payments, and the use of casino value instruments. Operators are expected to have a working compliance programme in place before they begin trading, not to build one afterwards.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 16 — establishes the supervisory framework covering designated sectors, including gaming operators.
· Commercial Gaming Policy Paper (NAMLCFTC), Section on risk-based supervision — sets out the sector’s ML/TF risks and the need for tailored AML controls.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.