What enhanced due diligence is required for VIP and high-value players in UAE gaming?

UAE
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What enhanced due diligence is required for VIP and high-value players in UAE gaming?

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UAE commercial gaming operators must apply Enhanced Due Diligence (EDD) to players who pose elevated money laundering risks, including VIP and high-value players. This obligation reflects international FATF standards and is embedded in both UAE AML law and the GCGRA regulatory framework.

The Commercial Gaming Policy Paper (GSNAMLCFTC, 2025) identifies VIPs and high-value players as a distinct risk category, noting that players who wager exceptionally large amounts present inherent ML/TF risks due to the volume and velocity of funds involved. EDD for these players requires gaming operators to collect additional identification information, verify the source of funds and source of wealth, and obtain prior senior management approval before opening or continuing the account.

EDD is also mandatory for Politically Exposed Persons (PEPs) under Article 16 of Cabinet Resolution No. 134 of 2025, which requires operators to establish risk management systems to identify PEPs, obtain senior management approval before establishing a PEP relationship, verify source of funds and wealth, and conduct enhanced ongoing monitoring.

The Commercial Gaming Policy Paper also specifies that high-risk players must be subject to tighter transaction scrutiny, more frequent updates to due diligence data, and increased vigilance around account and transaction activity. Any unusual patterns, particularly large deposits followed by rapid withdrawals without significant gaming activity, must be escalated and potentially reported to the FIU.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution No. 134 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