What are the Player Due Diligence requirements for gaming operators in the UAE?
Player Due Diligence (PDD) is the gaming-sector equivalent of Customer Due Diligence (CDD) under UAE AML law. Under the GCGRA’s Executive Regulations, gaming operators must apply PDD measures when a player’s transactions reach or exceed AED 11,000, as established in Cabinet Resolution No. 134 of 2025.
PDD requirements include: independently and reliably verifying the player’s identity using reliable documentation; establishing and assessing the nature of the relationship with the player; conducting a risk assessment of the player and assigning a risk rating; screening the player against targeted financial sanctions lists and checking for adverse media or criminal history; monitoring the player’s transaction behaviour on an ongoing basis; and reviewing the risk rating periodically and whenever risk factors change.
Gaming operators must document each stage of the PDD process and retain those records for a minimum of five years. The policy framework emphasises the use of technology-driven dynamic risk rating models to enable near-real-time assessment of player behaviour. Where a player presents a higher risk, for example, a politically exposed person or a player from a high-risk jurisdiction requires Enhanced Due Diligence (EDD), rsenior management approval for the account and verification of the source of funds and wealth.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, DNFBP Definitions — AED 11,000 PDD threshold for gaming operators
- NAMLCFTC, Commercial Gaming Policy Paper, Section 2.1.2 — Detailed PDD requirements for licensed gaming operators including identity verification, risk rating, and EDD triggers
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.