Must UAE gaming operators appoint a Money Laundering Reporting Officer?

UAE
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Must UAE gaming operators appoint a Money Laundering Reporting Officer?

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Yes. Commercial gaming operators in the UAE are legally required to appoint a Money Laundering Reporting Officer (MLRO) as a mandatory component of their AML/CFT governance framework. This requirement mirrors the Compliance Officer obligation applicable to all DNFBPs under UAE AML law.

Article 22 of Cabinet Resolution No. 134 of 2025 requires all Designated Non-Financial Businesses and Professions, including commercial gaming operators, to appoint a Compliance Officer at management level. The officer must have independence in decision-making, possess appropriate competence and experience, and fulfil specific statutory duties.

The Commercial Gaming Policy Paper (GSNAMLCFTC, 2025) specifies additional sector-specific requirements for gaming MLROs. The MLRO must: regularly reside in the UAE; have sufficient authority and access to operational information; be responsible for day-to-day management of AML compliance activities; serve as the internal point of contact for suspicious activity reports from gaming staff; liaise with the GCGRA and FIU; create and sustain annual training programmes for gaming employees; and report on key AML risks, issues, and trends to senior management on a semi-annual basis.

The MLRO duties include reviewing internal STR referrals and submitting reports to the UAE Financial Intelligence Unit via the goAML portal when required. Records of all MLRO decisions - including decisions not to file an STR and the reasons therefor - must be maintained under Article 25 of Cabinet Resolution No. 134 of 2025.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.

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