Do UAE gaming operators have to screen customers for PEPs and sanctions?
Yes. A commercial gaming operator must operate risk management systems to determine whether a customer or beneficial owner is a politically exposed person, and must implement targeted financial sanctions instructions without delay. Screening applies both at onboarding and throughout the relationship.
Where a customer is a foreign politically exposed person, the operator must obtain senior management approval before starting or continuing the relationship, take reasonable measures to establish the source of wealth and funds, and apply enhanced ongoing monitoring. Any confirmed match against a UN or UAE sanctions list must trigger the required freezing and reporting steps. Given the cash-intensive nature of the sector, effective screening is central to a defensible AML programme.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 16 - politically exposed person measures.
· Federal Decree-Law No. 10 of 2025, Article 19(1)(e) - immediate implementation of targeted financial sanctions.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.