How should UAE gaming operators verify a player’s source of funds?
UAE gaming operators should verify a player’s source of funds as part of due diligence, and apply enhanced checks for high-value or high-risk players. This means obtaining and, where possible, documenting evidence of where the money being staked comes from, such as salary, business income, or the sale of an asset, and confirming that it is consistent with what the operator knows about the player.
For VIP and high-stakes customers, the policy paper for the sector recommends documented source-of-funds and source-of-wealth checks, due diligence on any intermediary handling payments, and senior sign-off before a high-value relationship proceeds. Red flags include reluctance to explain the origin of funds, use of multiple or opaque payment methods, and third-party funding. Where the source cannot be satisfactorily established, the operator should decline the transaction and consider filing a suspicious transaction report.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 16 — requires enhanced measures including establishing source of funds and source of wealth for higher-risk customers.
· Commercial Gaming Policy Paper (NAMLCFTC), Section on due diligence and monitoring — recommends source-of-funds and source-of-wealth checks for VIP players.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.