Within how many working days must a UAE gaming operator report a sanctions freeze to the authorities?
Five working days. Once a gaming operator identifies a confirmed match against the relevant sanctions or terrorist lists, it must implement targeted financial sanctions immediately, which means freezing assets without delay and without prior notice and suspending the related accounts. The reporting of those actions to the appropriate authorities must follow within five working days.
The sequence matters. Freezing comes first and is not conditional on regulatory acknowledgement. The operator must not tip off the player that a match has been identified or that a freeze has been applied, and must not allow the player to withdraw funds or convert a balance while the match is being resolved. Screening obligations run continuously across players, transactions and business relationships, not only at account opening, which is why operators are expected to subscribe to the national notification arrangements so that list updates are picked up promptly.
Violating instructions issued in relation to targeted financial sanctions is a criminal offence carrying imprisonment and a fine of not less than AED 20,000, or either penalty. Screening and freezing evidence should be retained for at least five years.
Legal Reference (UAE):
· Commercial Gaming Policy Paper, Section 2.1.2 — sanctions compliance, immediate freezing and reporting within five working days
· Federal Decree-Law No. 10 of 2025, Article 33 — penalties for violating targeted financial sanctions instructions
For more details, consult the full text of the Commercial Gaming Policy Paper or seek guidance from your AML compliance officer.