Do gaming chips count as a financial transaction for AML in the UAE?
No. For the purpose of the AML customer due diligence trigger, a transaction that solely involves gaming chips or gaming instruments is expressly excluded from the definition of a financial transaction. The AED 11,000 threshold that requires due diligence is measured against the movement of funds, not the mere exchange of chips at the table.
This does not mean chip activity is irrelevant to AML. Buying in with cash, cashing out, or converting winnings involves funds and can bring a customer over the threshold or generate suspicion in its own right. Operators should monitor patterns such as minimal play followed by large cash-outs, which are classic layering indicators, and report where suspicion arises regardless of the chip exclusion.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3(1) - excludes pure gaming-chip transactions from the financial-transaction definition.
· Federal Decree-Law No. 10 of 2025, Article 18 - duty to report suspicion regardless of value.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.