Must a UAE commercial gaming operator appoint a compliance officer?
Yes. Like all DNFBPs, a commercial gaming operator must appoint a compliance officer at management level who has independence in decision-making and appropriate competence and experience. In the gaming sector this role is commonly described as the money laundering reporting officer.
The officer monitors transactions for crime indicators, reviews records, receives and assesses internal suspicion reports, and decides whether to notify the FIU through goAML, keeping those decisions confidential. They own the sanctions decision, manage the relationship with the supervisor and the FIU, retain reporting acknowledgements, and must ensure staff are trained. The individual needs enough seniority to act on their own judgement and to escalate without interference.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 22 - appointment and duties of an independent compliance officer.
· Federal Decree-Law No. 10 of 2025, Article 19(1)(d) - internal policies approved by senior management.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.