Officially, the United Arab Emirates (UAE) came into being in 1971. Back then, the desert expanse was limited in its urbanisation – cities like Abu Dhabi and Dubai were in development, with multi-storey buildings, roads and amenities available, but to nowhere near the scale they are today. Indeed, while oil had been discovered among the former seven Trucial Sheikhdoms in the previous decade, it was the decades to follow that would go on to put the newly formed Asian nation on the map.
Free zone areas to operate business with limited tax, the world’s only seven-star hotel and the world’s tallest building, the Burj Khalifa, came in 1985, 1999 and 2009 respectively. The turn of the millennium saw the UAE not only comfortable in its wealth, but able to use it to build structures bigger and bolder than anywhere else in the world. It also marked a shift in strategy for economic growth. Oil is a limited resource, after all.
Money from business and tourism is now a key priority for the UAE. When visiting, tourists come to see the world’s biggest mall, largest water park or biggest picture frame. It is excess and escapism combined with luxury; words that could also easily befit the land-based casinos of Macau and the Vegas Strip.
So, when Wynn Resorts announced plans to begin construction on the nation’s first land-based casino in 2022, interest was piqued. At the time, gaming was unregulated in the UAE. In fact, bar a few exceptions, gambling of any kind was banned in the nation, due to Islamic practices followed by law. But, of course, this did not mean there was no gambling.
Before regulation, “there were lottery and raffle offerings that existed in an unregulated environment,” Bishop Woosley, Director of Lottery Operations at The UAE Lottery, tells Gambling Insider. “They were popular and people enjoyed them. I think it’s one of the impetuses of the regulatory structure the regulator created and now exists – to bring that demand into a regulated environment.” Indeed, “years of unregulated gaming” is potentially a contributing factor in the decision to establish regulation. “In any jurisdiction where gaming is unregulated, eventually the decision will be made that it would be better to be regulated for player safety and integrity purposes. It is better to regulate than to try and control it constantly,” Woosley adds.
However, what licensed gaming also brings is tax revenue. Whether from locals or tourists, gaming is a lucrative business, with the European Gaming and Betting Association (EGBA) reporting that gross gaming revenue (GGR) from Europe alone generated €123.4bn ($133.2bn) in 2024, while the American Gaming Association reported FY24 gaming revenue of $71.92bn, up 5% and 7.5% respectively year-on-year. As the UAE looks to continue diversifying its revenue streams by establishing future-proof industries, gambling presents an option that ticks a lot of boxes, with luxury land-based experiences for tourists and high-earning locals balanced with online gaming and lottery for the typical UAE resident.
But, to have a licensed industry, you need licensees...
The GCGRA and getting there first
In recent years, rules on gaming have changed. September 2023 saw the UAE form its federal gaming regulatory body, the General Commercial Gaming Regulatory Authority (GCGRA), with Ex-MGM Chairman and CEO Jim Murren as Chair, and ex-Gaming Laboratories International (GLI) VP of Government Relations and General Counsel, Kevin Mullally, as CEO. This, naturally, led to Wynn receiving its licence to operate land-based gaming in the region. But, it was not the only operator to receive a licence.
In fact, Wynn was not even the first operator to receive a licence from the GCGRA. This accolade instead went to The Game LLC, who would operate the nation’s first authorised lottery, aptly named the UAE Lottery. At the time, Murren, Chairman of the GCGRA, said: “The launch of the UAE Lottery is a pivotal event that not only marks the establishment of a disciplined world-class regulatory framework for lottery activities but also underscores our commitment to nurturing a secure and enriched commercial gaming environment in the UAE.”
But how does one go about receiving the first regulatory licence from a jurisdiction? In terms of the measures taken, Woosley says it required “building out the infrastructure, the personnel, our own gaming system, making sure we were compliant with all regulatory frameworks, making sure we had internal legal and compliance functions that could help us follow and be aware of what the requirements were; and then building internal technical infrastructure so we would be ready. We would have a system, platform, staff and structure so the GCGRA would be comfortable giving us an operational licence.
“It was a huge effort in a very short time period. But the company has done an excellent job of bringing in gaming professionals from all over the world (more of this later) with various expertise and knowledge. Obviously, that culminated in us winning the licence.”
Casino-wise, Wynn received its gaming licence in early October 2024, allowing the operator to continue to development of its 1,500-room property on Al Marjan Island. In the iGaming space, meanwhile, Aristocrat was able to secure the nation’s first gaming-related vendor licence (Novomatic followed as the second) for both land-based and digital gaming at the tail-end of October. Aristocrat Gaming’s VP of Commercial for EMEA & Latam Andrew Sackey tells Gambling Insider: “At Aristocrat, we are always looking for opportunities to be a first mover in all markets as we continue to focus on growth as a key pillar of our business – across land-based gaming and online. The UAE has always been a growth target for EMEA. and there is a lot of interest and excitement around the impact that it could have on the global gaming market.”
But what is the process of gaining a licence from a newly established regulator like? While it could be expected that the process would be bumpy and unpolished, for Aristocrat, this was far from its experience. “The UAE has some of the finest regulatory professionals in the world working alongside applicants who are interested in participating in their business,” says Sackey. “We consider it a privilege to have worked alongside them. We saw some similarities to other markets given the involvement of GLI and other governing bodies, so it was helpful to have that baseline and scale to help drive our application process forward.”
Around the world
As both Woosley and Sackey mentioned, both the GCGRA and the operators applying for licences from them consist of teams from all over the world. Murren, for example, is the former Chairman and CEO of MGM Resorts, while CEO Mullally was the VP of Government Relations & General Counsel at GLI for over a decade, with other accomplishments including an almost five-and-a-half-year long stint as Executive Director of the Missouri Gaming Commission. The GCGRA came into the industry with the experience to run an expansive operation – and given expectations for what this market may become, that experience will be invaluable.
The global makeup of the GCGRA and the regulated businesses operating in the UAE is reflective of the UAE as a whole. According to statistics, less than 15% of the UAE’s population are native Emiratis, with the majority of citizens being expats from South Asia, Egypt and the Philippines, as well as America, Europe and other locations. This is exacerbated by the nation’s growing tourism industry, which in 2023 accounted for 11% of the nation’s GDP as it welcomed over 28 million hotel guests across over 210,000 rooms.
When helping the lottery’s foundation, Woosley utilised his experience of helping start the Arkansas Lottery in 2009. “When you start, you have an assumption,” he says. “Then, players generally change that assumption fairly quickly, because it’s what they like that is going to dictate what we sell and how we market.” Only being a few months into its time in the UAE, Woosley and The UAE Lottery team are still learning about their players. Finding out what incentivises them to play, what they don’t like (“which is really nothing at this point,” Woosley commented) and when they are most active is still being understood. This last point in particular brought up the idea of seasonality, when players are more or less engaged with play due to things such as holidays and customs. “I’m getting a hold of the culture [in the UAE] now,” he says. “Sometimes when it’s very hot, people go away, or they don’t go outside. Or, during holidays, they go back to the country they’re from. We’re trying to grab a hold of that and understand when people are buying. If a lot of the population has left the country, [we can] form our marketing around that and create a marketing campaign for the country that resonates but also is respectful of the culture. We’re learning and hopefully as we go, we’ll refine it and become UAE lottery experts.”
Overall, the UAE will present businesses with a unique yet lucrative, opportunity for expansion. It is likely we will see experimentation from operators in the early period as it gathers data on player behaviour, though alongside this, the market will also have to compete with one other in particular...
Facing up to Macau
Of course, while all of this suggests a market with promise on the horizon, the UAE will have one major competitor to contend with when it opens its integrated resort(s): Macau.
For perspective, Macau’s legalised gaming market was established around 130 years before the UAE was even officially unionised. For a brief summary of this history, Pedro Cortés, Managing Partner at Lektou, tells Gambling Insider: “Macau’s history as a gaming hub dates back to the late 1840s when the Portuguese Government legalised gambling to generate revenue following the first Opium War and the Hong Kong occupation by Great Britain. Over the years, Macau developed a reputation for its casinos and gambling culture. The real transformation began in 2002 when the Government of Mr. Edmund Ho, following the handover in 1999, decided to end the monopoly system and open the market to more operators.”
In the last 20 years, operators from across the globe have staked their claim in Macau, with operators including Wynn, Las Vegas Sands and MGM Resorts operating one or multiple properties. Local operators, including Melco Resorts, Galaxy Entertainment Group and SJM also operate in the region. As of 2019, there were a total of 41 casinos in Macau.
When you start, you have an assumption. Then, players generally change that assumption fairly quickly, because it’s what they like that is going to dictate what we sell and how we market - Bishop Woosley, Director of Lottery Operations at The UAE Lottery
Already, the UAE and Macau share a similarity, with local and global operators flocking to a market to fuel growth and competition. Another shared trait between the two can be described as opulence: Consider the size, scale and grandeur of Macau’s casino hotels (and the money put behind their construction). This, naturally, drives tourism, though in the case of Macau, this tourism is known to largely be driven by mainland China – something that caused issues during and directly after the Covid-19 pandemic, as Cortés writes that an “over-reliance on gaming revenue made Macau vulnerable to economic fluctuations and policy changes in China.”
Moreover, while both benefit largely from tourism, the tourism brought to Macau is largely gaming-based. Consider that, in Q4 2024, MGM Resorts’ Las Vegas Strip properties made $2.22bn in revenue, of which $501m, or 22.6%, was reported in casino revenue ($822m, or 37%, came from room revenue in the same period). Compare this to MGM China, which of its $1.02bn revenue, $885m, or 86.8%, came from casino revenue.
Diversity in non-gaming options has been a major talking point in Macau for some time, though “the success of these efforts has been mixed,” according to Cortés. “There has been growth in non-gaming sectors, with increased investment in entertainment, retail and hospitality. However, gaming still dominates Macau’s economy and the transition to a more diversified revenue base is ongoing.”
But, even with diversification efforts ongoing, Macau’s gaming market is not easy competition. While the UAE’s gaming offering will likely cover a broader scope, potentially inspired by lessons learned from Macau’s gaming-centric market, Macau has established itself as a prime gaming location, with its history and casino offerings making it unlikely to simply bow out with a new player on the scene.
UAE v Macau: Is there only room for one at the top?
“The UAE’s development of a regulated online and land-based gaming industry could pose a threat to Macau’s dominance, as its strategic location and regulatory framework could attract international players and operators,” says Cortés, when assessing the UAE’s potential as a threat to Macau’s dominance. “Furthermore, the UAE’s focus on both land-based and online gaming could provide a more comprehensive gaming experience.”
In Cortés’ view, “the advanced infrastructure and technology that can support a robust gaming industry, a well-regulated market that can attract reputable operators and ensure player protection and the UAE’s appeal as a luxury destination, which can draw high-spending tourists,” are factors that could give the UAE a competitive edge. As such, Macau will be required to continue its development of non-gaming options to draw in players – something the region has been attempting to implement in recent years. Although compared to other gaming destinations like Vegas, its split in revenue between gaming and non-gaming options swings wildly towards the former.
Another decisive factor, Cortés adds, is Macau’s “needs to continue introducing new gaming experiences and technologies and ensuring a fair and transparent regulatory environment to attract international operators.”
For both Cortés and Woosley, Macau’s lack of an online gaming market marks a distinct gap in the region’s armour. While his experience specialises in lottery specifically, Woosley says: “Opportunities for online gaming exist here that do not exist there.” Cortés went further to produce a list of pros and cons for a regulated online gaming market in Macau (which “some years ago was a discreet part of public speeches. It seems such legalisation is not on the horizon”), where he notes “avoiding online gambling regulation helps maintain control over the gaming industry and prevents potential issues related to online fraud and addiction,” and that “it allows Macau to focus on its strength in land-based casinos, which are a significant tourist attraction.”
However, when it comes not regulated iGaming, Cortés’ list was slightly more extensive. “Macau misses out on potential revenue from the growing online gambling market,” he says and “other regions with regulated online gambling may attract a broader audience.” However, most notably, “the illegal online market will continue to be the only option for Macau residents and, despite the recent enacted law on unlawful gambling that criminalised the activity even if the servers are located outside Macau, the fact is that legalisation and regulation of the activity could, on the one hand, prevent the illegal market from growing. On the other hand, it could be another source of revenue, attracting online operators to the market.” Much like Woosley said earlier, “It’s better to regulate it than to try and control it constantly.” Though, the potential of a regulated iGaming sector in Macau is a much wider topic to explore in another issue.
There has been growth in non-gaming sectors, with increased investment in entertainment, retail and hospitality. However, gaming still dominates Macau’s economy and the transition to a more diversified revenue base is ongoing - Pedro Cortés, Managing Partner, Lektou
However, it seems not all in the industry see one market as destined to cannibalise the other. When asked if the UAE was a threat to Macau’s dominance, Sackey says: “Not necessarily, as markets are added to the iGaming sector, we believe it increases opportunity for our customers and players. The growth indicates support and regulatory management of this exciting space in gaming.”
Moreover, in spite of the market’s potential, it does not guarantee that the UAE will come to overshadow its eastern neighbour. In Cortés’ view, Macau “will continue to be the largest gambling jurisdiction, with the attempt of the successive Governments to diversify the economy.” He cited the entry of global casino brands as bringing “significant capital, expertise and high-quality facilities, with a robust tourism infrastructure, including luxury hotels, entertainment venues and shopping centres” to the area, which, given the region’s 2024 gross gaming revenue of MOP 226.8bn ($28.34bn), presents a hard act for the UAE to follow.
Looking to the future
Everything said in this article is done so with an understanding that the UAE market is barely out of its infancy. The UAE Lottery has been operating for less than a year and, as of writing, Wynn Al Marjan has yet to open its doors. But, this does not mean the industry cannot speculate on what’s to come.
Woosley expects the market to grow quickly – much like the UAE itself. “If you have paid attention and have been very closely watching what is happening here, it’s like everything else in the UAE. It moves very fast, and is set up incredibly fast in a well-done manner. We got a licence to operate lottery in June. We launched in November. That’s pretty fast. If you look at other jurisdictions in the US, that took almost two years to launch from the time they were created and awarded a licence.
“I would think for most of the verticals, especially those that are online, it’s going to happen even faster. It’s the intent of the GCGRA, and I won’t speak for them, to award operational licences to those that can get up and running as fast as possible. That probably includes all verticals. So you’re going to see a fairly expansive environment in the next five years.”
Of course, entering a new market also means making a good first impression. For Aristocrat, striving to “be the best partner to our customers and a worthy licensee within the UAE” is at the top of the supplier’s agenda. “We will be bringing our latest hardware and games to the market to support the emerging market, and we will support the operators and regulator develop the framework allowing adoption of any new approved technology,” says Sackey.
Combine these two factors; a fast-paced yet well-regulated developing market, and companies ready to impress, and what we see is a market that, on paper, will certainly turn heads. But the UAE does not exist in a bubble. The growth of the UAE will also likely impact the development of other Asian markets, from longstanding institutions like Macau to emerging markets in Thailand and Japan. In Cortés’ opinion, in five years, “the Asian gaming market is likely to be more diversified, with several key developments.” These include established gaming industries in the aforementioned emerging markets, the development of regulated online gaming and a “trend towards integrated resorts offering a mix of gaming and non-gaming amenities.”
Indeed, “there is a lot of interest and excitement around the impact the UAE could have on the global market,” in Sackey’s view. “As the newest jurisdiction, these new entertainment options enhance an already attractive country.”
However, it would be wise to not put all your eggs in the UAE basket just yet. The nation’s first casino hotel is still in development, and alongside having to compete with any other casino hotels that come later down the line, they will also need to compete with the offerings of other iconic hotel destinations in the nation. Al Marjan Island, where Wynn is building its inaugural UAE property, is an hour’s drive from Dubai Airport, and two hours from Zayed International Airport in Abu Dhabi. Ifit wants guests to come, they need those willing to stay, using their time and potentially forgoing other tourist destinations.
When people think of Nevada, people think of Vegas. While tourists may also want to visit the Grand Canyon or Area 51, it does not quite have the same impact. With so many tourist destinations already available in the UAE, there may be concern that the different segments of the tourism industry will begin to compete with each other – beneficial to national GDP, but a challenge for individual industries.
Moreover, while the online industry offers diversity, online gaming is best targeted at locals, rather than tourists. Again, finding out the UAE’s online gaming player base and appealing to the needs of an international population will take time. But what will come of the industry is yet to be seen. While financial backing and an established operator run by industry veterans is a good sign, competition in Asia is rife, and there is no guarantee for success. While the odds do seem to be in the industry’s favour, it is, as they say, a gamble.
