The United Arab Emirates (UAE) is vigorously developing its gambling industry and has issued commercial gambling regulations and licensing materials. For interested investors and licensees, the good news is that the regulatory and licensing framework is similar to mature US jurisdictions such as Nevada and New Jersey.
The UAE consists of seven emirates, namely Abu Dhabi (the federal capital), Dubai (arguably the most famous), Ajman, Fujairah, Sharjah, Ras Al Khaimah, and Umm Al Quwain.
With the establishment of the General Commercial Gambling Regulatory Authority (GCGRA) and the government's clear support for introducing gambling, these conflicts seem to be resolved soon.
The GCGRA, established in September 2023, is a federal agency in the UAE responsible for overseeing all aspects of commercial gambling and gambling within the country. It has exclusive rights to regulate, license, supervise, and enforce gambling regulations.
The GCGRA board includes experts in gambling, sports betting, and related legal fields, led by Chairman Jim Murren, former CEO of MGM Resorts International and a member of the American Gaming Association Hall of Fame. The GCGRA is also responsible for overseeing the enforcement of gambling-related regulations.
With the support of an executive management team with extensive industry and regulatory experience, the GCGRA effectively launches and regulates gambling activities in the UAE. The GCGRA's regulatory scope includes common casino table games and gaming machines, online gaming, lotteries (whether cash or prizes), and sports/event betting.
However, the GCGRA does not regulate the marketing activities of the gambling industry.
The GCGRA issues five types of licenses, divided into two categories: entity licenses and individual licenses.
Entity licenses cover gambling operators, gambling-related suppliers, and key corporate entities, while individual licenses apply to key individuals and gambling employees. Applicants must notify the GCGRA of their application intentions and complete the designated application process, and pay applicable fees. Licensees must comply with various obligations related to financial crime prevention, advertising standards, regulatory cooperation, responsible gambling frameworks, and technical standards.
For many US operators and suppliers looking to do business in the UAE, the licensing system should be familiar.
The GCGRA has released a comprehensive licensing guide, which provides information about the licensing process, as well as important definitions about who must be licensed and ultimately under the jurisdiction of the GCGRA, including the mandatory licensing definition of "control"—a crucial consideration for companies seeking to enter the UAE market.
Like many other jurisdictions, applicants need to demonstrate their eligibility for a license through "clear and compelling" evidence, including overall suitability.
One potential risk to note is that under the current structure, the GCGRA has significant power and discretion to decide who meets the standards and who does not. Although this is no different from other jurisdictions, there are currently no provisions for formal appeals if applicants or operators disagree with the GCGRA's compliance decisions.
Furthermore, the GCGRA has adopted many of the same gaming certification standards ("GLI Standards") used in various jurisdictions worldwide. Although the framework is the same, so far, the GCGRA seems to have adopted a generic standard approach rather than a prescriptive one. In other words, the GCGRA sets expectations but does not specify the details of how to meet these expectations—a method generally favored in the gaming industry.
The UAE's entry into the international gambling field is a significant development and offers substantial opportunities for investors in the industry. The PASA team will continue to monitor these developments, but if you have any questions or need assistance to better understand the potential opportunities these developments bring, please contact us.
