UNITED ARAB EMIRATES Trends and Developments Contributed by: Stuart Paterson, Janine Mallis and Tania Forichon, Herbert Smith Freehills (Dubai)
cerning the legal classification of digital assets, especially for asset tracing purposes. Legalising Gambling With gambling outlawed in the UAE, the intro - duction of a new federal regulatory body, the General Commercial Gaming Regulatory Author - ity (GCGRA), in September 2023 established a regulatory framework for national lottery opera - tions and commercial gaming in the UAE for the first time in the country’s history. Gaming is now regulated through the issuance of licences, and entities wishing to engage in commercial gaming activities in the UAE must obtain a licence from the GCGRA following the guidance provided in the GCGRA’s guide pub - lished on 1 May 2024. The licensing process requires preliminary screening, preparation and submission of business proposals, assessment and evaluation, and ongoing compliance and monitoring.
In 2022, casino operator Wynn Resorts announced that it would build a luxury resort in Ras Al Khaimah (an emirate in the north of the UAE, approximately a 45-minute drive from Dubai) with “gaming area” . The resort was recently granted the first-ever commercial licence for gaming operations. Further, on 28 July 2024, the GCGRA awarded its first lottery licence to “The Game LLC” . An increase in financial crime is, however, clearly on the cards. In jurisdictions that permit gam - bling, there are typically concerns that casinos, by the nature of their cash-intensive operations, attract criminals looking to launder funds. In many cases, criminals can take advantage of the anonymity provided by casinos which do not have rigorous KYC and customer due diligence (CDD) processes in place. In 2023, Australia’s largest casino operator, Crown Resorts, was fined AUD450 million after it was discovered that the company allowed gamblers to move money through non-transparent channels.
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