Federal Gaming Regulatory Authority – the GCGRA
Established in September 2023, the General Commercial Gaming Regulatory Authority (GCGRA) regulates all commercial gaming activities in the UAE. Notably, the GCGRA board is led by Jim Murren, former CEO of MGM Resorts International. The similarly qualified executive team is led by Kevin P. Mullally – an experienced gaming regulator. The GCGRA unveiled its regulatory framework, and announced that under that framework, it has awarded its first license to The Game LLC, a commercial gaming operator who will operate the UAE’s first authorized lottery.
Scope of Regulation
The GCGRA regulates “Commercial Gaming”, which it defines as “any game of chance, or combination of chance and skill, where an amount of money, in cash or cash equivalents, is wagered – i.e. placed as a bet – for the purpose of winning a sum of money or other valuable items.” Examples provided include lottery, internet gaming, sports wagering, and land-based gaming facilities (i.e., casinos).
Crucially, the GCGRA does not regulate “promotional activities”, which are activities or expenses that are promotional in nature (e.g., a marketing campaign that includes a prize draw). The GCGRA has sole discretion to determine whether an activity is Commercial Gaming or only promotional, but has provided a few criteria that guide its determination: objective of the promotion, fair market value of any required purchase, and the treatment of the prize as a marketing cost.
Licensing
According to its website, the GCGRA issues two main types of licenses:
1. Entity Licenses
a) Gaming Operators:
Entities operating internet gaming platforms, sports wagering, and land-based gaming facilities, as well as the lottery and lottery retailers.
b) Gaming-Related Vendors (For suppliers of commercial gaming-related goods/services):
Suppliers of commercial gaming equipment or related goods and services.
c) Key Person Corporate (For entities managing or controlling gaming operations):
Entities holding decision-making roles within the ownership structure of applicants/licensees, including but not limited to controllers, affiliates, or management service providers.
2. Individual Licenses
d) Key Person Individual:
Individuals holding executive decision-making roles within applicants/licensed entities, including but not limited to directors, executive officers, or controllers.
e) Gaming Employees:
Individuals working for, or otherwise connected with, applicants/licensees.
To apply for a license, an applicant must first notify the GCGRA of its intention to apply by completing an intake form. Once considered eligible to apply, an applicant would gain access to a licensing portal where its full application and supporting documentation can be submitted.
Once licensed, licensees are subject to ongoing reporting and compliance requirements. Licensees who fail to comply with these requirements are may be subject to a revocation of their licenses, a monetary fine, and/or any other administrative measure taken against them.
Looking Ahead
This new framework represents a significant development for the UAE and the region. It presents new opportunities for the gaming industry and sets the stage for further innovation and growth in the sector.
If you have any questions about this development and the opportunities it presents, our Gaming team would love to hear from you. Please do not hesitate to contact us at 1-800-604-1312or via our contact page https://segevllp.com/contact-us/.
