What enhanced due diligence applies to VIP players and high-value customers in UAE gaming operations?
VIP players and high-value customers at UAE gaming facilities are subject to Enhanced Due Diligence (EDD) under the GCGRA’s AML framework, which implements the requirements of Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025. EDD is mandatory where the player’s risk rating is elevated, which is typically the case for VIP accounts, high-volume players, politically exposed persons (PEPs), or players from higher-risk jurisdictions.
Under EDD, gaming operators must go beyond standard Player Due Diligence and: obtain verification of the player’s source of funds and source of wealth; secure senior management approval before establishing or continuing the relationship; apply enhanced and more frequent transaction monitoring; conduct deeper background checks including adverse media screening; and review the EDD profile at shorter intervals than for standard-risk players.
The Commercial Gaming Policy Paper published by NAMLCFTC identifies VIPs and high-value players as a specific risk category, noting that their high transaction volumes, cross-border activity, and access to premium facilities create elevated exposure to both money laundering and sanctions risk. Operators must document every EDD measure applied and retain those records for at least five years. Failing to apply EDD to a player who meets the risk criteria constitutes a compliance failure under the GCGRA’s regulatory framework.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 19 — EDD requirements for higher-risk customers applicable to all DNFBPs including gaming operators
- NAMLCFTC, Commercial Gaming Policy Paper, Section 3.7 — VIPs and high-value players identified as a specific ML/TF risk category requiring EDD
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.