What are the penalties for AML non-compliance by gaming operators in the UAE?
Commercial gaming operators in the UAE that fail to comply with AML/CFT obligations face severe penalties under both the primary AML law and sector-specific regulations. The UAE 2025 legal framework significantly strengthened the penalty regime compared to its predecessor.
Federal Decree by Law No. 10 of 2025, the UAE primary AML law establishes criminal liability for money laundering offences, with imprisonment terms of up to 10 years and fines of up to AED 100 million (approximately USD 27 million) for organisations that violate the AML framework. Individual directors, officers, and employees can face personal criminal liability alongside the gaming entity itself.
Administrative penalties for specific compliance failures, such as failure to apply Player Due Diligence, failure to file Suspicious Transaction Reports, inadequate record-keeping, or failure to appoint a Money Laundering Reporting Officer, are prescribed under Cabinet Resolution No. 71 of 2024 (on violations and administrative penalties for DNFBP AML obligations). The GCGRA, as the sector AML supervisory authority, also has independent enforcement powers, including suspension or revocation of gaming licences.
The Commercial Gaming Policy Paper (GSNAMLCFTC, 2025) notes that the penalty framework is designed to be proportionate but sufficiently deterrent to ensure that the commercial gaming sector meets international AML standards from inception.
Under Article 25 of Cabinet Resolution No. 134 of 2025, failure to maintain records as required - including AML records, CDD documentation, and STR files - is itself a punishable offence, separate from any underlying substantive AML failure.
Legal Reference (UAE):
- Federal Decree by Law No. 10 of 2025, Primary AML law establishing criminal and administrative penalties for gaming operators
- Cabinet Resolution No. 134 of 2025, Article 25, Record-keeping obligations, breach of which carries independent penalties
For more details, consult the full text of FDL No. 10 of 2025 or seek guidance from your AML compliance officer.
Guide to Cabinet Resolution No. 134 of 2025 on AML Law No. 10 of 2025