What are the main money laundering risks in the UAE commercial gaming sector?
The national policy paper for the UAE commercial gaming sector identifies several inherent money laundering and terrorist financing risks. These include anonymous transactions, the exploitation of player accounts, third-party payments, transactions linked to foreign jurisdictions, the use of multiple and opaque payment methods, and potential employee complicity.
Additional concerns highlighted for the sector include the use of casino value instruments, VIP programmes that attract high-net-worth and cross-border customers, and heavy cash usage. Each of these can be used to disguise the origin of illicit funds or to move value with limited traceability. The paper recommends completing a sectoral risk assessment as a foundational step, then adopting proportionate, risk-based mitigation such as stricter due diligence, transaction monitoring, technology-driven supervision, and strong internal controls and staff training.
Legal Reference (UAE):
· Commercial Gaming Policy Paper (NAMLCFTC), Executive Summary and key issues — lists the sector’s principal ML/TF risk factors and recommended mitigations.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 5 — requires operators to identify, understand, and assess their crime risks using a risk-based approach.
For more details, consult the full text of the Commercial Gaming Policy Paper or seek guidance from your AML compliance officer.