iGaming In The UAE: The Impact Of The Regions First Lottery License

Following the recent announcement that the GCGRA granted the first lottery license in the UAE, we spoke with SANDRA Mottoh LLB MSc , to hear her insights on what this exciting development means for the future of the iGaming industry in the region. Sandra shares a fresh perspective from her regulatory expertise in banking, while also discussing some of her life reflections and her latest venture – Responsible Gaming MENA.

What are your insights on the first lottery license being granted by the GCGRA??

The GCGRA was launched by the federal government in September last year. The intention is to progressively create a regulated commercial gaming ecosystem which in the UAE had previously been regarded as ‘haram’, translating as ‘forbidden’ in Arabic. Over the past few months, the GCGRA has been hiring new people and working hard to ensure they quickly have a robust regulated framework in place.

The first exciting development has been publicly issuing a regulated license for the UAE National lottery. Whilst it is still very early days, this first GCGRA license and accompanying regulatory framework is in my estimate, an important foundation in building a robust licensing regime, setting out as it does what the regulator will expect of any firm that wants to enter the sector and how they must go about attaining a license to operate. It will of course be illegal to undertake commercial gaming without having a fully authorised license. As such firms new to the Region and the new licensing regime will undoubtedly require specialist guidance from local businesses with expert insight and knowledge to help navigate their way through the emerging licensing process.

The next phase will be making sure that early licensed entities are able to run their business in a way that the GCGRA has approved. Ensuring any new gaming entity transparently conducts themselves in a highly responsible manner will be key to a wider, new social acceptance of activities that were until very relatively recently regarded as 'haram'. In a society previously conservative and cautious about activities such as gaming, this will require overt demonstration of the adoption of highly responsible practices.

How new gaming businesses project, communicate, and advertise their new services will be of particular focus for the gaming regulator. Specific advertising rules will be part of the emerging and robust GCGRA regulatory environment to ensure that only credible, well-run enterprises are able to be active in the new gaming market and that they promote their services in a highly responsible manner.

From a wider perspective, one of the key aspects I love and value most about the advent of the GCGRA is that whilst its remit is clearly to sponsor and support responsible gaming, in so doing it will also be a key enabler of creating yet more economic growth and prosperity for the region by generating more tourism, hospitality, and leisure customers for the UAE. A lottery alone is a great example of this wider benefit; not only do individuals stand to win sizeable amounts of money for a very small investment but, based upon experiences elsewhere in the world, implementing a lottery has the potential to generate significant revenues for the good of the wider society.

Whilst no formal decision has yet been announced, the word on the street is that the UAE government is considering imposing a 25% revenue tax on lottery ticket purchases. So, for every 100 AED per play, 25% of the revenue generated will go directly to the government for potential use on worthwhile projects benefiting all citizens. The residual revenue take will, of course, be used to fund operational costs and significant lottery prizes. The advent of a regulated gaming industry in the UAE will add to the attractiveness of a highly vibrant, tax-free location for a very diverse population of expats and locals alike. It’s definitely exciting times!

Has there been any noticeable changes in local attitudes toward iGaming recently?

In the UAE, the word ‘gaming’ is used interchangeably between video gaming and online gaming. When it comes to online gaming, key players must tread a lot more carefully than with pure video gaming. The UAE recognises the recreational and commercial values, as well as the link to tourism and the ecosystem that comes with iGaming. As such the government has clearly realised that if it does not tap into this market now then substantial opportunities may be missed.

When I first moved to the UAE eight years ago, I was brought in to set up and operationalise a regulatory compliance function in Audit within an Islamic bank I therefore have a unique insight into the ‘haram’ nature of certain commercial activities, iGaming being one of them. In Islamic banking, charging interest is not allowed. Instead, other methods have been put in place to ensure that banks can still generate some revenue for services rendered. The same goes for iGaming - the UAE government has looked under the hood and realised what the stumbling block is that makes this a forbidden activity. If it is the case that we need to prevent it from being addictive or keeping financial wellness intact, infrastructure can be created for that. Therefore, a whole host of businesses that can provide a safety net to this environment are being set up.

Overall, there has been shift in attitudes locally because people see the GCGRA as being willing to focus on overly avoiding the societal ills that can plague the gaming industry; this will provide comfort and reassurance to many. The easing of attitudes has been gradual, and it will undoubtedly be a slow evolution as the GCGRA only published in their initial rules at the end of July 2024. Momentum will continue to grow as people and businesses hear and learn more and more about this newly emerging sector. For someone like me who is already a participant in the sector and coming from the experience of banking and specifically Islamic banking, I am very excited with the direction of travel and can see the value of a strong regulatory regime that will provide comfort and reassurance for a diverse and multicultural society.

I have realised that my skillset of working with best-practice compliance and regulation matters gained from financial service organisations provides a great platform to help participants in the new UAE commercial gaming space. As a result, I took the plunge to set up my own consultancy named Responsible Gaming MENA .

At Responsible Gaming MENA , we support entities to prepare for initial licensing and to operationalise GCGRA regulatory requirements on an ongoing basis. The second part is ensuring entities comply with GCGRA advertising standards - I will review and endorse all marketing and advertising collateral for my clients before publication. The third fold which is super exciting is the training piece. ?I will be providing training to gaming licensee on the required compliance standards. Additionally, and over the longer-term, it is my intention to work with universities to educate young adults who will inevitability be participants in iGaming to ensure they understand and know how to do so in a responsible way. This would include how they can prevent addictive behaviours from developing. Together I see that ensuring regulatory compliance, fostering adherence to firm advertising rules, and providing quality training at all levels will help in the growth and development of the new UAE gaming market.

How has the experience of relocating to the UAE been, especially when it comes to raising children there?

For me, I have had a great journey in the UAE. I met my now husband, we got married and had our two children here which has been a delightful experience for me.

For young children, they are living their best life here I must say! They are living an admired life that in the UK they may have not had access to in terms of the diverse population, access to world-class education, and quality entertainment. I love that my children get to grow up in a place that is inherently safe, and they aren’t exposed to what I would call the ‘adult perspective’ at such a young age; they can grow up as children. Access to childcare is also much cheaper in the UAE which is a bonus.

In certain aspects, there are flexible working options available.? Employers are becoming open to hybrid working environments. Although more could be done, there is a visible shift in the right direction. For example, I have my physical office which is my firms working space. But I also have the best of both worlds. I get to remain corporate and interact with corporate entities, but I can also define my hours and work flexibly in a way that suits me. It’s not flexible because I have children, its flexible because this is the way the world is going. I cannot stop working because it is 4pm or 6pm. Depending on client needs, I may have to log on at 9pm therefore I have to be flexible with them. Life is much more flexible, and so is work, and that’s in my company ethos to reflect what my clients want, but also what I want as well.

In the past 8 years that I’ve been here, I have seen a remarkable shift which has been extremely positive, and I can only imagine what the next 8 years has in store.

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Could you shed some light on the opportunities available in the UAE for women in the gaming industry?

In UAE, the potential opportunities are vast. It’s only ‘potential’ because it’s a newly developed ecosystem. We can also gain insight from other sectors such as banking. I would say iGaming mirrors what banking is, because it is what we call an ‘underground bank’ per se. Women initially were not so highly represented in banking because traders or technologists for example were predominantly male. But as every sector grows and develops, you will find departments within that sector that lend itself to skills that women bring to the table.

I haven’t come from a traditional gaming background; I’m not a gamer or developer, however I can use my transferrable skills from banking. I’m legally qualified and I went into regulatory compliance after university over 22 years ago. I recognised iGaming would benefit my skillset, and it gave me the idea to start up my consultancy to provide that service to a new sector. For me as a woman, the market is fully open because my skills are required. When you have a skillset that is attractive, it’s not really gender based. Any new sector would say we need competent people who can help us grow.

I would encourage any woman who wants to enter the iGaming industry to look at the entire ecosystem and determine what services are needed. It’s all about your competence in the sector and what you bring to the table. I would urge the iGaming industry to realise that they shouldn’t take a narrow view on how they select their talent. What I mean here is not just choosing people who have worked in iGaming all their lives, but to think a little bit more dynamically.

What advice would you offer to someone considering an iGaming career in the UAE?

When I was coming here eight years ago, I was scared. Human beings fear change; we say we want it but when the options are on the table we are scared because we want what we are used to around us. A wise person told me you have a 3- or 6-month probation with a new job – take your probation as what it is. Go for the 3 or 6 months the company have offered you. If you like it, you stay, if you don’t like it, you come home. And that’s what I would say for anyone looking to come to the UAE or considering entering the iGaming industry. If you are looking to change sectors, give it a go. Lead with your area of competency, and if you don’t like it, step back into what you are used to because your sector will always receive you well.

We would like to extend a special thank you to SANDRA Mottoh LLB MSc for her participation in today's article. We can't wait to witness the progression of the UAE as an iGaming hub following the recent announcement of the first lottery license being granted in the region.