Must UAE gaming operators screen players against sanctions and PEP lists?
Yes. UAE gaming operators must screen customers and their beneficial owners against applicable sanctions lists and must have systems to determine whether a customer or beneficial owner is a politically exposed person. Sanctions screening is a continuous obligation, so operators need to check both at onboarding and on an ongoing basis as lists are updated.
If a player matches a sanctions listing, the operator must freeze without delay and follow the required notification steps rather than simply declining the play. For a politically exposed person, the operator must establish appropriate risk management systems, obtain senior management approval before proceeding, take reasonable measures to establish the source of funds and wealth, and apply enhanced ongoing monitoring. These controls address the sector’s exposure to high-net-worth and cross-border customers.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 16 — sets the requirements for identifying and handling politically exposed persons.
· Federal Decree-Law No. 10 of 2025, Article 16 — places operators under supervisory oversight for measures including targeted financial sanctions screening.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.