What AML governance must a UAE commercial gaming operator’s board put in place?
A UAE commercial gaming operator’s board carries ultimate responsibility for AML compliance and must put in place a governance framework that makes the programme effective. This starts with approving written AML/CFT policies and procedures, ensuring an institutional risk assessment is carried out and kept up to date, and overseeing the work of the compliance officer.
The board must ensure the operator appoints a competent money laundering reporting officer with real authority, provides regular staff training, applies player due diligence and enhanced due diligence where required, screens for sanctions, reports suspicious activity to the FIU, and retains records for at least five years. An independent audit function should test whether these controls work. Senior management oversight and a documented risk-based approach are what supervisors look for when assessing the maturity of an operator’s defences.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19: requires internal policies and controls approved by senior management and a documented risk-based approach.
· Cabinet Resolution No. 134 of 2025, Article 21: requires internal controls and an independent audit function to test their effectiveness.
For more details, consult the Commercial Gaming Policy Paper or seek guidance from your AML compliance officer.