How must UAE gaming operators screen players against sanctions lists?

UAE
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How must UAE gaming operators screen players against sanctions lists?

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Sanctions screening is a mandatory AML obligation for commercial gaming operators in the UAE. Gaming operators must maintain systems capable of screening players, transactions, and business relationships against relevant sanctions and terrorist lists on an ongoing basis.

The Commercial Gaming Policy Paper (GSNAMLCFTC, 2025) specifies that gaming operators must comply with Cabinet Decision No. 74 of 2020 (Regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions), which establishes the UAE Targeted Financial Sanctions (TFS) framework. Under this framework, operators must screen regularly against: the UAE domestic terrorism lists; the UN Security Council consolidated sanctions list; and any other lists designated by competent UAE authorities.

Where a confirmed match is identified, gaming operators must immediately: freeze assets without delay and without prior notice; suspend related accounts immediately; and report the action to appropriate authorities within five working days.

The Commercial Gaming Policy Paper also requires operators to subscribe to the UAE automatic reporting system for sanctions lists to receive real-time updates on newly listed persons or entities, ensuring prompt identification.

Article 15 of Cabinet Resolution No. 134 of 2025 prohibits all DNFBPs, including gaming operators, from opening or maintaining anonymous accounts or accounts held under fictitious names, reinforcing the identity verification requirements that underpin effective sanctions screening. Gaming employees responsible for sanctions functions must receive tailored AML training at least once per calendar year.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Decision No. 74 of 2020 or seek guidance from your AML compliance officer.

Guide to Cabinet Resolution No. 134 of 2025 on AML Law No. 10 of 2025