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The United Arab Emirates is developing its casino market around regulation, tourism integration, and controlled access rather than broad gaming expansion, according to Macau-based lawyer Sofia Linhares. She said the country is taking a different approach from traditional gaming jurisdictions by setting up its regulatory framework before the industry reaches maturity.
Regulation First Approach
Speaking to AGB, Linhares said the UAE’s move into gaming should not be seen as a shift toward unrestricted gambling. Instead, she described it as the creation of a controlled entertainment sector operating within a defined legal framework under the General Commercial Gaming Regulatory Authority.
According to her, the legal environment has changed from being one of total ban to regulation, which allows for controlled permission. This change, according to her, ensures more certainty for the licensed companies, the providers, and other businesses that operate within the gaming industry environment.
Linhares noted that the UAE was not opening its doors to free market gaming. In her view, the country is making a carefully calibrated statement that it is serious about building a regulated ecosystem.
Unlike established gaming markets that developed their regulatory structures over decades, the UAE is designing its framework before a large-scale casino industry has emerged. Linhares said that it allows the country to build compliance requirements into the system from the outset, including stronger oversight of operators, suppliers, and financial activity.
She added that the UAE is designing for a post-junket world from day 1, with a heavier emphasis on technology, data transparency, and anti-money laundering infrastructure. This is indicative of a growing trend in other gaming jurisdictions that have developed in recent times, whereby there is a growing need to focus on the issues of responsible gaming, financial controls, and transparency prior to the establishment of commercial operations.
Gaming As Tourism Support
Linhares said one of the UAE’s main advantages is that it does not need casinos to create tourism demand. She pointed to the country’s diversified economy, world-class tourism infrastructure, and non-gaming hospitality sector, which already outperforms many gaming destinations.
Unlike some markets where integrated resorts were built primarily to attract visitors, the UAE already has an established luxury tourism base. Linhares said gaming should therefore serve as an additional attraction rather than the foundation of the destination.
She said the UAE does not need gaming to fill hotels or drive footfall. Rather, she believes that the market requires gaming to complement a pre-existing ecosystem.
Staying in that balance will be the biggest challenge facing the market, she said. In her opinion, most jurisdictions had integrated resorts developed as diverse tourist attractions but were later dependent on gaming income.
Linhares said the risk is complacency. If operators treat non-gaming as a marketing line rather than a business model, she warned, the UAE could follow the same trajectory as others. She said regulators will need to ensure that non-gaming components remain supported through transparent reporting, performance monitoring, and clear standards for integrated resort development.
Wynn Al Marjan Test
The opening of Wynn Al Marjan Island will be the first major test of whether the UAE’s approach can work in practice. The $5.1 billion resort in Ras Al Khaimah, developed by Wynn Resorts with local partners, is expected to include the UAE’s first licensed casino alongside hotels, dining, entertainment, and other non-gaming facilities.
Linhares said the project represents more than the introduction of casino gaming. In her view, it will test whether gaming can operate within a broader tourism model that remains aligned with the country’s economic priorities.
While Macau’s gaming industry evolved over decades before tighter regulatory controls were introduced, Linhares said the UAE has the opportunity to build safeguards before the sector matures. She said the key lesson is to regulate the ecosystem, not just the operator, adding that Macau’s greatest failure was allowing the junket system to operate in regulatory twilight while generating revenue without meaningful oversight.
The long-term challenge for the UAE, she said, will be maintaining a balance between attracting international gaming investment and preserving a broader tourism-led economic model.
Source: Asia Gaming Brief
