Do UAE gaming operators need to appoint a Money Laundering Reporting Officer?
Yes. UAE gaming operators must appoint a compliance officer at management level, commonly called a Money Laundering Reporting Officer, who has independence in decision-making and appropriate competence and experience. This person owns the AML programme and is the point of contact for the Financial Intelligence Unit and the sector supervisor.
The officer’s duties include monitoring transactions for links to crime, examining and assessing internal reports of suspicion, deciding whether to file suspicious transaction reports through goAML, keeping records, and ensuring staff are trained. Given the transaction volumes typical of gaming, the officer needs adequate resources and often technology support to be effective. The role must have genuine authority to act on suspicions without interference, and appointing it in name only, without real seniority or independence, is treated by supervisors as a compliance failure.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 22 — requires an independent compliance officer at management level and sets out the role’s duties.
· Federal Decree-Law No. 10 of 2025, Article 16 — establishes supervisory oversight of these obligations.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.