What are the AML record-keeping requirements for gaming operators in the UAE?

UAE
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1

UAE gaming operators, as DNFBPs, are required under Article 19(b) of Federal Decree-Law No. (10) of 2025 to retain all AML-related records for a minimum of five (5) years from the date of the last transaction or the end of the business relationship, whichever is later.

Records that must be retained include:

  • Customer identification documents — copies of passports, Emirates IDs, or equivalent documents collected during CDD
  • Beneficial ownership records — documentation of UBO identification for corporate customers
  • Transaction records — details of all transactions above CDD thresholds, including date, amount, payment method, and player identity
  • CDD and EDD files — all due diligence records, risk assessments, and supporting documentation for each customer
  • STR documentation — records of all STRs filed, including the analysis that led to the filing (noting that STR contents are confidential)
  • Training records — logs of AML training delivered to staff

Records must be stored securely with controlled access and be retrievable promptly upon request by the GCGRA or other competent authorities. Electronic storage is acceptable provided records are protected against alteration and backed up.

Legal Reference (UAE):

Records should be organised and indexed to allow rapid retrieval during regulatory inspections or law enforcement requests.

Further reading: Commercial Games in AML — AML UAE

2

Commercial gaming operators are DNFBPs when they conduct a single financial transaction, or several apparently linked transactions, worth AED 11,000 or more. A transaction involving only gaming chips or gaming instruments does not count for that purpose. Once in scope, the general record-keeping rules apply.

That means keeping transaction records for at least five years from completion of the transaction or the end of the business relationship, and keeping the due diligence file for at least five years from the latest of relationship termination, account closure, completion of an occasional transaction, completion of a supervisory inspection, completion of an investigation, or a final judgment. The due diligence file expressly includes CCTV recordings, which matters more for gaming floors than for most sectors.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 3(1): commercial gaming operators are DNFBPs at or above the AED 11,000 threshold, excluding transactions solely in chips or gaming instruments.

· Cabinet Resolution No. 134 of 2025, Article 25(1) and (2): the five-year retention periods, expressly including CCTV and ATM recordings.

Where the position is finely balanced, document your reasoning and raise it with your compliance officer.

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