When must a UAE gaming operator conduct enhanced due diligence on a player?
A UAE gaming operator must conduct enhanced due diligence whenever a player presents a higher risk of money laundering or terrorist financing. Clear cases include politically exposed persons, players connected to high-risk countries identified by the National Committee, high-value or VIP customers, and any relationship or transaction that is unusually large or has no apparent lawful purpose.
Enhanced measures include obtaining additional information on the player’s identity and the source of funds and wealth, understanding the purpose of the relationship, securing senior management approval before proceeding, and applying closer ongoing monitoring. For gaming, the sector’s exposure to cross-border and high-net-worth customers makes these checks especially important. The operator should record why a player was rated higher risk and what extra steps were taken, so the decision can be justified to the supervisor.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 16 — sets enhanced measures and senior management approval for politically exposed persons.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 23 — requires enhanced due diligence for dealings linked to high-risk countries.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.