At what transaction threshold must UAE gaming operators apply customer due diligence?
UAE gaming operators must apply customer due diligence for single or linked transactions at or above the prescribed threshold for the sector, alongside the standard triggers of suspicion of a crime or doubts about earlier identification data. Where a customer breaks a large amount into several smaller transactions that are linked, the operator must aggregate them and treat the combined value as meeting the threshold.
Threshold-based CDD does not remove the wider duty to monitor. Even below the figure, an operator that suspects money laundering or terrorist financing must carry out due diligence and consider a report. Above the threshold, the operator must identify and verify the customer and, where relevant, the beneficial owner using reliable independent sources before completing the transaction. Structuring play to stay under the limit is itself a recognised red flag that should prompt closer scrutiny.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 7 — sets the cases, including threshold transactions, in which CDD applies.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 9 — requires identification and verification from reliable, independent sources.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.