How should UAE gaming operators manage the risk of anonymous transactions?
Anonymous transactions pose one of the highest ML risks in the gaming sector, as they allow criminals to introduce illicit cash into the financial system without being identified. The UAE’s Commercial Gaming Policy Paper (2025) recommends several targeted controls to address this risk.
Key mitigation measures include:
- Mandatory identity verification at or before the AED 11,000 CDD threshold — no anonymous chip purchases above this level should be permitted
- Restrict large cash transactions — implement internal limits on cash chip purchases below the regulatory threshold where risk warrants it
- Card-based or traceable payment methods — encourage or require the use of identifiable payment channels (debit cards, bank transfers) rather than cash
- Cumulative transaction monitoring — track multiple smaller transactions from the same player across a session or defined period to detect structuring
- Enhanced scrutiny for multiple payment methods — any player using three or more payment methods in a session should trigger an enhanced review
- Real-time monitoring technology — deploy automated systems to flag anonymous or high-risk transaction patterns as they occur
Operators should document their anonymous transaction controls in their AML policy and train gaming floor staff to identify and escalate suspicious patterns.
Legal Reference (UAE):
- Commercial Gaming Policy Paper (NAMLCFTPC, 2025) — anonymous transaction risk and mitigations
- Federal Decree-Law No. (10) of 2025, Article 19 — ongoing monitoring and CDD obligations
- Cabinet Resolution No. (134) of 2025 — CDD thresholds and simplified/enhanced CDD rules
All anonymous transaction incidents should be documented, even where no STR is ultimately filed, to support the firm’s audit trail.
Further reading: Commercial Games in AML — AML UAE