The European Commission’s recent decision to remove the United Arab Emirates (UAE) from its list of high-risk third countries with strategic deficiencies in
The European Commission’s recent decision to remove the United Arab Emirates (UAE) from its list of high-risk third countries with strategic deficiencies in anti-money laundering (AML) and counter-terrorism financing (CFT) regimes is generating significant positive implications across various industries, particularly for the burgeoning gaming sector. Legal expert Luís Portela de Carvalho, a Partner at Lektou specializing in gaming, media, and entertainment law, has provided insights into what this pivotal development means for the industry.
Portela de Carvalho stated, as reported by iGaming Times, that the most significant implication of the UAE’s removal from the European Commission’s high-risk AML/CFT list is the “marked reduction in compliance and regulatory obstacles” for operators and investors. He conveyed, as reported by iGaming Times, that this “burdensome layer of scrutiny has now been largely eliminated, rendering the UAE market more accessible and appealing to gaming operators wishing to expand or enter new partnerships.” He also noted that this decision was “largely anticipated” and no surprise, following the UAE’s earlier removal from the Financial Action Task Force’s (FATF) grey list in early 2024. He explained, as reported by iGaming Times, that the UAE’s progress in overhauling its regulatory regimes and strengthening enforcement mechanisms was widely publicised, leading many industry stakeholders to foresee the EU’s delisting as a natural follow-up to the FATF’s ruling.
The UAE’s delisting from the high-risk lists follows several years of aggressive regulatory reform. These initiatives included steep fines against financial institutions, the introduction of new AML legislation, and the launch of a national strategy for 2024-2027. Portela de Carvalho explained, as reported by iGaming Times, that the UAE’s “sweeping reforms were pivotal,” citing publicly disclosed fines on banks and exchange houses in 2023 and 2024 that totalled millions of dirhams, demonstrating the seriousness of these measures. He added, as reported by iGaming Times, that the UAE’s regulatory overhaul showed “a commitment to transparency, security, and international standards”-a vital message for stakeholders evaluating long-term investment risk. While cautioning that operators should “continually remain vigilant, as they would in any market,” Portela de Carvalho was unequivocal, as reported by iGaming Times, that “It does not appear premature to view the UAE as a low-risk jurisdiction,” as the FATF’s comprehensive review, followed by the European Commission’s subsequent confirmation, relied upon demonstrated compliance with international AML/CFT standards.
For the gaming sector in particular, the timing of the delisting is highly favourable. The UAE has taken cautious but notable steps toward liberalising gambling, including establishing the General Commercial Gaming Regulatory Authority (GCGRA) and issuing several licences in recent months. Portela de Carvalho stated, as reported by iGaming Times, that “The UAE was already an appealing jurisdiction for online gambling operators,” and that “The recent delisting only amplifies the country’s credibility by mitigating concerns over heightened scrutiny.” He suggested, as reported by iGaming Times, that the combination of regulatory maturity and EU approval sends “a global endorsement of its regulatory strength,” positioning the UAE as a “preeminent regional hub for gaming operators.”
For operators and investors based in the EU, the delisting is expected to result in a marked change in how they can engage with UAE-based partners or customers. Portela de Carvalho advised, as reported by iGaming Times, that “EU-based gaming companies should view the UAE as a significantly more straightforward and commercially advantageous market.” He explained that the relaxation of enhanced due diligence requirements results in decreased compliance costs and simplifies cross-border transactions. Moreover, he noted, the delisting “harmonises the UAE with other jurisdictions that enjoy greater ease of commerce within the global gaming ecosystem.”
Asked whether the UAE is likely to further reinforce its legal framework to maintain its new low-risk status, Portela de Carvalho explained, as reported by iGaming Times, that the GCGRA has already taken a proactive approach. He added that given the UAE’s demonstrated commitment to meeting global standards, it is likely that the country will “build upon its existing foundations, tightened guidelines, and policies.” Portela de Carvalho concluded, as reported by iGaming Times, that for a global gaming sector seeking credible, stable jurisdictions with growth potential, the UAE’s delisting is “more than a technical update,” it’s a “green light,” conveying a strong message to the international community that the UAE upholds robust standards in matters of financial integrity and security. He believes it should “instil further investor confidence and propel accelerated growth within this sector.“
The UAE’s removal from the EU’s high-risk AML list marks a pivotal moment for the gaming sector, significantly reducing compliance burdens and amplifying the country’s credibility as a regional hub for operators. This development, driven by years of aggressive regulatory reform, is expected to accelerate growth and foster greater international investment, particularly from EU-based companies, as the UAE continues to proactively strengthen its financial integrity frameworks.
