Are gaming chips excluded from AML transaction thresholds in the UAE?
Yes. Under Cabinet Resolution No. 134 of 2025, the Executive Regulations to Federal Decree-Law No. 10 of 2025, there is a specific clarification that a financial transaction shall not include a transaction that solely involves gaming chips or gaming instruments. This means that the exchange of chips between players, or the use of chips within the gaming facility without any cash or monetary conversion, does not count toward the AED 11,000 threshold that triggers Player Due Diligence obligations.
However, this exclusion is narrow and does not extend to the initial purchase of chips using cash or other payment methods, nor to the redemption of chips for cash or equivalent value. Those transactions do constitute financial transactions for AML purposes and count toward the AED 11,000 threshold. If a player’s chip purchases, redemptions, or other monetary transactions reach or exceed AED 11,000 in a single transaction or in linked transactions, the gaming operator must apply Player Due Diligence.
Operators should be alert to players who structure chip purchases and redemptions to stay below the AED 11,000 threshold, as this may constitute structuring, a red flag for money laundering that requires internal escalation and potential STR filing regardless of whether the individual transaction threshold is met.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, DNFBP Definitions, Explicit exclusion of chip-only transactions from the financial transaction definition; AED 11,000 threshold applies to monetary transactions
- NAMLCFTC, Commercial Gaming Policy Paper, Section 3.6, Casino and betting value instruments identified as a specific ML risk requiring controls
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.