Who is responsible at board level for AML compliance in a UAE commercial gaming operator?
The board of directors of a licensed gaming operator is responsible for overseeing the AML compliance framework, including the policies, procedures and activities implemented to reduce money laundering risk. Responsibility cannot be pushed down to the Money Laundering Reporting Officer alone.
In practice the board must satisfy itself that the operator’s AML risk management framework is fit for purpose and that its policies, systems and controls actually meet the regulatory requirements. That means approving the institutional risk assessment, approving the AML policy, receiving reporting on key risks and issues, and holding management to account for remediation. The Money Laundering Reporting Officer is required to report on key risks, issues and trends to senior management on at least a semi-annual basis, which gives the board a defined reporting rhythm to work from.
The General Commercial Gaming Regulatory Authority is the AML/CFT supervisor for the sector and applies a risk-based supervisory model. Board minutes evidencing genuine challenge of the AML framework, rather than passive receipt of a compliance paper, are what distinguish effective oversight from nominal oversight during supervisory review.
Legal Reference (UAE):
· Commercial Gaming Policy Paper, Section 2.1.2 — governance and oversight, board responsibility for the AML compliance framework and MLRO semi-annual reporting
· Cabinet Resolution No. 134 of 2025, Article 21 — internal AML policies must be approved by senior management
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.
AML regulations for commercial gaming operators in UAE