How is commercial gaming defined under UAE AML law?
Under Cabinet Resolution No. 134 of 2025, the Executive Regulations to Federal Decree-Law No. 10 of 2025, “commercial gaming” is defined as any game of chance, or any form of opportunity-based or practice-based activity that relies on chance and skill, in which a specific monetary amount is placed as a stake with the objective of winning a monetary amount or any other item of value.
This definition encompasses a broad range of gaming activities that fall under the regulatory jurisdiction of the General Commercial Gaming Regulatory Authority (GCGRA). The GCGRA was established as the sole federal body mandated to regulate, license, and supervise all commercial gaming activities and facilities in the UAE, headquartered in Abu Dhabi. The categories of gaming operators classified as DNFBPs for AML purposes include: land-based gaming facility operators (including those operating on board vessels or marine craft), internet gaming operators, sports wagering operators, and lottery operators.
Gaming activities not explicitly authorised under the GCGRA framework are deemed illegal and subject to enforcement action. The Commercial Gaming Policy Paper issued by the National Committee on AML/CFT (NAMLCFTC) highlights that the inclusion of commercial gaming in the DNFBP framework reflects the sector’s inherent money laundering risks, including anonymous transactions, cash handling, high-value play, and cross-border exposure.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, DNFBP Definitions, Definition of commercial gaming and gaming operator categories subject to AML law
- NAMLCFTC, Commercial Gaming Policy Paper, Section 1.2, Background on the GCGRA mandate and AML risk profile of the commercial gaming sector
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.