What AML risks arise from third-party payments in UAE commercial gaming?
Third-party payments are identified as a key inherent money laundering risk for the UAE gaming sector, alongside anonymous transactions, exploitation of player accounts, foreign jurisdiction transactions, opaque payment methods and employee complicity. The concern is straightforward: when the person funding play is not the person playing, the audit trail between the source of funds and the beneficiary of the payout breaks.
Typical patterns include deposits made from a bank card or account in another person’s name, cash presented at the cage by a companion, funding routed through an intermediary who aggregates money from several players, and withdrawals requested to a destination account that does not belong to the player. Each of these breaks the link that player due diligence is designed to establish.
The mitigation is to require that deposits and withdrawals move through a verified player account in the player’s own name, to reject or escalate payments where the payer and player do not match, to establish the relationship and rationale where a third party is genuinely involved, and to treat repeated third-party funding as an enhanced due diligence trigger requiring source of funds and source of wealth evidence and senior management approval.
Legal Reference (UAE):
· Commercial Gaming Policy Paper, Executive Summary — third-party payments identified as a key inherent ML/TF risk for the sector
· Cabinet Resolution No. 134 of 2025, Article 23 — enhanced customer due diligence proportionate to the level of risk
For more details, consult the full text of the Commercial Gaming Policy Paper or seek guidance from your AML compliance officer.