UAE off EU risk list: what it means for gaming, according to legal expert Portela de Carvalho
The recent decision by the European Commission 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 waves across industriesnone more so than gaming. Speaking to SiGMA News, , Partner at and a recognised expert in gaming, media, and entertainment law, broke down what this means for the sector.
“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,” said Portela de Carvalho. “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.“
The EU risk list now excludes the UAE, following its earlier removal from the Financial Action Task Force’s (FATF) grey list in early 2024. According to Portela de Carvalho, this sequence was no surprise.
“The decision was largely anticipated,” he noted. “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.“
Regulatory pivot
The UAE’s delisting follows several years of aggressive regulatory reform. These included steep fines against financial institutions, new AML legislation, and the launch of a national strategy for 2024C2027.
“The UAE’s sweeping reforms were pivotal,” explained Portela de Carvalho. “Publicly disclosed fines on banks and exchange houses in 2023 and 2024 totalled millions of dirhams, demonstrating the seriousness of these measures.”
He added 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 some might caution against assuming permanent low-risk status, Portela de Carvalho was unequivocal.
“It does not appear premature to view the UAE as a low-risk jurisdiction,” he said. “The FATF’s comprehensive review, followed by the European Commission’s subsequent confirmation, relied upon demonstrated compliance with international AML/CFT standards.“
That said, he still advised caution: “Operators should continually remain vigilant, as they would in any market.”
Momentum for gaming sector
For the gaming sector in particular, the timing is 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.
“The UAE was already an appealing jurisdiction for online gambling operators,” said Portela de Carvalho. “The recent delisting only amplifies the country’s credibility by mitigating concerns over heightened scrutiny.”
According to him, the combination of regulatory maturity and EU approval sends “a global endorsement of its regulatory strength,” making the UAE a “preeminent regional hub for gaming operators.”
Barriers falling
Operators and investors based in the EU should see a marked change in how they can engage with UAE-based partners or customers.
“EU-based gaming companies should view the UAE as a significantly more straightforward and commercially advantageous market,” Portela de Carvalho advised. “The relaxation of enhanced due diligence requirements results in decreased compliance costs and simplifies cross-border transactions.”
Moreover, he explained, the delisting “harmonises the UAE with other jurisdictions that enjoy greater ease of commerce within the global gaming ecosystem.”
Staying off the list
Asked whether the UAE is likely to further reinforce its legal framework to maintain its new low-risk status, Portela de Carvalho explained:
“The GCGRA has already taken a proactive approach,” he said. “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.”
For a global gaming sector hungry for credible, stable jurisdictions with growth potential, the UAE’s delisting is more than a technical update. It’s a green light.
“This development conveys a strong message to the international community that the UAE upholds robust standards in matters of financial integrity and security,” Portela de Carvalho concluded. “It should instil further investor confidence and propel accelerated growth within this sector.“
