Are online gaming platforms in the UAE classified as DNFBPs under AML law?
Yes. Internet gaming operators in the UAE are explicitly classified as Designated Non-Financial Businesses and Professions (DNFBPs) under Cabinet Resolution No. 134 of 2025. This means that online gaming platforms licensed and operating in the UAE are subject to the full suite of AML/CFT obligations under Federal Decree-Law No. 10 of 2025, on the same basis as land-based gaming facilities.
Internet gaming platforms must comply with AML requirements including: conducting Player Due Diligence (PDD) for transactions at or above AED 11,000; assigning risk ratings to players at the time of account creation and reviewing those ratings periodically; applying Enhanced Due Diligence (EDD) to politically exposed persons (PEPs), high-risk players, and customers from higher-risk jurisdictions; screening players against targeted financial sanctions lists and adverse media; reporting suspicious player activity to the Financial Intelligence Unit (FIU) via goAML; retaining records for at least five years; and appointing an MLRO with appropriate seniority and independence.
The General Commercial Gaming Regulatory Authority (GCGRA) serves as the AML supervisory authority for internet gaming platforms. The GCGRA Commercial Gaming Policy Paper specifically identifies online gaming’s risks as including anonymous account creation, multiple payment methods, and third-party payment exploitation, all of which require robust technology-enabled controls.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, DNFBP Definitions, Internet gaming operators explicitly classified as DNFBPs subject to UAE AML law
- NAMLCFTC, Commercial Gaming Policy Paper, Section 2.1.2, AML/CFT provisions specific to online gaming
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.