The UAE has made a decisive push into regulated gaming, becoming the first market in the GCC to roll out a national commercial gaming framework, after Wynn Resorts’ planned USD 3.9 bn gaming resort gave a boon to the sector. The GCGRA followed up with a national lottery license for the Game, and issued various other gaming-related vendor licenses, allowing them to supply data, live casino, and B2B gaming content into the UAE market.

But with the roll-out comes new concerns and regulatory questions, as federal and emirate-level law attempt to regulate on-the-ground enforcement. A new report (pdf) by global gaming advisory firm SCCG finds that the early phase is already exposing regulatory ambiguities — especially when it comes to how each emirate is enforcing federal-level legislation.

How it currently works

What we know so far: In the UAE, no legacy gaming case law exists, so enforceability is being created through regulation. Federal law sets the base, GCGRA rules carry immediate force, and license terms and contracts fill the gaps. Together, lawyers at Al Kabban & Associates Sara Al Kabban and Christa Hyman said, this “creates a legally robust framework even in the absence of historical jurisprudence.”

For online gaming, the GCRA is expected to adopt a one-license-per-emirate model, mirroring the framework used for land-based casinos. This means that while gaming is regulated at the federal level, execution still depends on emirate-level participation, particularly online.

Centralization matters: SCCG founder and CEO Stephen A. Crysta argues the federal layer is the system’s stabilizer. “In the US, it’s very much state by state, with very little role for the federal government, and that causes friction,” he said. “So far, the feedback in the UAE has been quite positive. People like the structure.” This follows Singapore’s approach — a massive Asian gaming market — as opposed to the US, he added.

Federal authority is clearer than it looks: While SCCG highlights overlap between federal and emirate oversight, Al Kabban argues the hierarchy itself isn’t in doubt. Because the gaming regulator was established by federal decree, its licences carry nationwide effect. “Rather than viewing them as discrepancies, they are jurisdictional variations that need to be accounted for,” the firm said — translating into extra procedures, not uncertainty.

Still, some gray zones do exist. Several platforms — like TrueWin and Dream Island — are operating online casino-like games without full licensing being rolled out yet. Both operate by “piggybacking” on The Game’s license, SCCG said.

The ambiguity is typical of the current transitional phase, Crystal said. “As you regulate, there is a transition process between the gray market and the regulated market,” he said.

But it’s a matter of time until authorities eventually have to clamp down on the irregularities, Crystal said. Allowing gray-zone activity to linger indefinitely would dilute license value, discourage compliant operators, and undermine long-term investment certainty, a lesson mature markets have already learned.

Other sticking points exist…

When it comes to payments and gaming revenues, it’s not straightforward either. Gaming revenue must be ring-fenced and handled through conventional (non-Islamic) banking channels, separate from non-gaming revenues, raising questions about whether financial separation limits the sector’s broader economic contribution.

Islamic banks cannot touch gambling proceeds, and even within conventional institutions, gaming accounts are segregated to prevent commingling — ensuring compliance with shariah principles while preserving auditability and AML oversight.

Al Kabban and Hyman also note that gaming is classified as a high-risk activity under UAE AML rules, which is why segregation is mandatory. “Ring-fencing is designed to prevent the commingling of gaming proceeds with other funds,” Al Kabban said. The result is heavier compliance, not a ceiling on growth.

The same logic applies to crypto. Direct crypto wagering remains off-limits, but licensed operators can use regulated exchanges as on-ramps, converting virtual assets into fiat before funds enter the gaming system.

Balance over velocity: Crystal sees the structure as deliberate calibration. “There has to be a balance between shariah law and local customs and norms and the best way to transact in the gaming industry,” he said, calling the reliance on conventional rails and crypto-to-fiat “the right balance.”

It’s not a major deterrent

Will friction scare off operators? Crystal doesn’t think so. Asked whether ring-fencing, patchy card acceptance, and crypto limits could deter global gaming groups, he was blunt: “I would say no.” In gaming, he argues, complexity is the norm, not the exception.

Technology as the shock absorber: “What’s significant about the gaming industry is the sophistication of its technology,” Crystal said, pointing to operators’ ability to ring-fence funds, deploy alternative payment routes, and meet KYC and AML requirements simultaneously. Having worked across more than 100 jurisdictions, he calls technology the industry’s “saving grace” — reducing friction while strengthening compliance, rather than cutting off access.

Plus, gaming is not just about what happens on the casino floor: “There are lots of ways from a non-gaming standpoint that the UAE will benefit,” he said, pointing to tourism, hospitality, entertainment, and corporate roles. In mature destination markets like Las Vegas and Macau, a large share of value accrues outside the casino floor.

Our take: That logic is clear in the UAE’s integrated-resort model. Casinos may anchor the system, but tourism and entertainment do much of the economic heavy lifting — and create the range of roles needed to support workforce localization over time.

Speaking of…

Labor is another unresolved tension: Emiratization requirements apply, but direct casino roles remain culturally sensitive. “Starting out, it may be a struggle,” Crystal said. “They may need to be creative,” pointing to a likely split between Emiratis in corporate, compliance, and oversight roles, and expatriates on gaming floors.

Al Kabban’s lawyers agree that UAE nationals will likely be placed in nationals in “administrative, compliance, and oversight functions,” calling it a practical way to meet obligations while respecting cultural sensitivities.

Growing pains, not red flags: Crystal is explicit that these frictions shouldn’t be overread. “Anytime you’re going from strict prohibition to permission, you’re going to have issues,” he said. “These are what I call growing pains.” In his view, the UAE’s infrastructure, regulatory resolve, and talent pipeline mean the system is designed to adapt (not stall) as the market matures.

Why all of this matters

The sector shows huge potential for economic contribution. Under a conservative path — which would see the UAE host one integrated resort and limited online gaming — annual revenue could reach USD 1.5-2 bn. A broader rollout, with multiple resorts and regulated online gaming in select emirates, lifts that figure to USD 5-6 bn.

The ceiling is much higher: In a fully expanded scenario — multiple integrated resorts plus nationwide online gaming — SCCG sees annual revenue climbing to USD 8-10 bn, approaching Singapore-scale outcomes over time.

Demand will not be an issue: “There is unlimited demand,” Crystal said. What separates the outcomes is alignment between federal rules, emirate-level execution, banking rails, labor policy, and enforcement once the market moves beyond licensing announcements.

A bid to set the model: “Right now, the UAE is learning from other markets,” he said. “In the future, other markets will learn from the UAE.” He points to the country’s blend of strict oversight and tech-led compliance as a potential global reference point — echoing a playbook the UAE has already deployed in newer sectors like crypto, which international observers have previously praised for regulatory clarity.