Gaming sector brought into UAE’s rigorous new AML laws

The move comes after the UAE cabinet issued decision 134 of 2025 (the AML regulation), which provides additional guidance on how to implement the new anti-money laundering, terrorism and weapons proliferation financing requirements set out in the November law (together the AML framework).

Under the new AML regulation, entities operating in the commercial gaming sector have now been included in the category of designated non-financial businesses and professions (DNFPBs), placing them alongside virtual asset service providers which had already been included in the scope of the new AML Framework.

Now, AML/CFT obligations are triggered in relation to transactions worth over AED 11,000 – either individually or as a series.  Marie Chowdhry, a financial regulation expert with Pinsent Masons in the Middle East, said the cabinet decision would be a transformative one in the country’s compliance landscape.

“The regulation not only strengthens AML/CFT obligations but also expands coverage to emerging sectors such as virtual assets and commercial gaming,” she explained.

“By addressing virtual assets, complex corporate structures, and newly regulated sectors such as commercial gaming, the UAE is tackling vulnerabilities that have historically been exploited in other jurisdictions for illicit financial flows.

“These measures underscore the importance of a dynamic compliance approach that evolves with market trends.”

The new AML framework means more stringent regulatory obligations, including record keeping and transaction monitoring for virtual asset providers, in line with traditional financial institutions, and requires all organisations that come under its scope to document and regularly update their due diligence procedures and risk assessments.

Stricter penalties have also been introduced, with fines of up to AED 100 million (around US$27 million) for organisations who violate the new AML framework, while individuals may face imprisonment for up to 10 years. The new AML framework also clarifies that funding offences can be committed via digital systems if the operator has awareness, even by implication, that the funds may be used for terrorist activities.

Companies will also face stricter requirements for maintaining clearer internal governance rules, including the requirement to have mandatory compliance officers and audit controls, putting more accountability on senior leadership teams.

“These regulations also signal the UAE’s commitment to global standards and its determination to mitigate financial crime risks across traditional and digital markets,” said Lana Akkad, a financial expert with Pinsent Masons in the UAE.

“For multinational corporations and cross-border gaming companies, this means harmonising their compliance frameworks across jurisdictions, including now, the UAE.”