Do lottery operators in the UAE have AML obligations under Federal Decree-Law No. 10 of 2025?
Yes. Lottery operators in the UAE are explicitly classified as DNFBPs under Cabinet Resolution No. 134 of 2025, the Executive Regulations to Federal Decree-Law No. 10 of 2025, and are therefore subject to the same AML/CFT obligations that apply to other gaming operators.
This classification covers all licensed lottery operators under the General Commercial Gaming Regulatory Authority (GCGRA), including the UAE Lottery and the two legacy airport lotteries that continue to operate under GCGRA supervision. As DNFBPs, lottery operators must: apply Player Due Diligence when transactions reach or exceed AED 11,000; screen players against targeted financial sanctions lists; appoint an MLRO with appropriate seniority; report suspicious transactions to the FIU via goAML without delay; maintain AML records for at least five years; and ensure the board of directors actively oversees the AML compliance programme.
Lotteries present specific ML/TF risks including the purchase of large volumes of tickets with cash, resale of winning tickets, and the potential for organised criminal groups to use lottery winnings to launder proceeds. NAMLCFTC has recommended completion of a sectoral risk assessment for the gaming sector to ensure the measures applied to lottery operators are proportionate to the actual risks identified.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, DNFBP Definitions — Lottery operators explicitly included as DNFBPs subject to AML obligations
- NAMLCFTC, Commercial Gaming Policy Paper, Section 1.2 — GCGRA mandated to supervise lottery operations including legacy airport lotteries
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.