What are the penalties for AML non-compliance by commercial gaming operators in the UAE?
Commercial gaming operators in the UAE that fail to comply with AML/CFT obligations face a tiered set of administrative penalties under Article 17 of Federal Decree-Law No. 10 of 2025, imposed by the General Commercial Gaming Regulatory Authority (GCGRA) as the designated AML supervisory authority for the sector.
Administrative penalties available to the GCGRA include: a formal warning; an administrative fine of not less than AED 10,000 and not exceeding AED 5,000,000 for each violation; prohibition from engaging in the sector relevant to the violation; restrictions on the powers of board members, executive or managerial personnel, or owners proven responsible for the violation; suspension of directors or senior management for periods determined by the GCGRA; suspension or restriction of the gaming licence; and revocation of the gaming licence in the most serious cases.
Beyond administrative penalties, individuals at the board and senior management level can be held personally liable for AML failures under the strengthened accountability framework introduced by Federal Decree-Law No. 10 of 2025. The 2025 legislation significantly increased penalties compared to the repealed 2018 law, with greater emphasis on senior management accountability. With FATF’s onsite mutual evaluation of the UAE expected in mid-2026, gaming operators are under heightened scrutiny to demonstrate genuine implementation of their AML controls.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 17 — Full schedule of administrative penalties for DNFBP AML violations, AED 10,000 to AED 5,000,000 per violation
- NAMLCFTC, Commercial Gaming Policy Paper, Section 2.1 — GCGRA’s enforcement powers and coordination with national AML bodies
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.