The first rule of casinos in the UAE: You do not talk about casinos in the UAE.
In a nation where alcohol is tightly regulated and public swearing is a punishable offense, gambling remains a cultural and legal taboo, forbidden for its local citizens. Yet, beneath the surface, the architecture of a multi-billion-dollar gaming industry aimed at foreigners is quietly being assembled.
The clues are hard to miss: a national gaming authority has been created, seasoned casino executives from Las Vegas are taking up residence in the Emirates, and an ambitious hotel project is already in motion. Just this weekend, Wynn Resorts said it received a license to operate a “gaming facility” in the UAE – the first of its kind.
Once fully realized, this industry could contribute up to 1.7% of the UAE’s GDP, potentially generating close to $10 billion annually — big for a country that, not long ago, was an expanse of untouched desert.
It would also mark one of the most profound cultural shifts in the UAE’s modern history. And for the past two years, the UAE government has been revealing its plans in slow, measured steps.
But those in the know are keeping quiet. Operators from Las Vegas remain tight-lipped, and insiders who understand the scope of what’s being built refuse to speak publicly.
The secrecy is understandable. Despite the flurry of behind-the-scenes activity, “gambling tools and machines” are still listed as restricted goods by the UAE government. There is no formal gaming law yet, the newly established gaming commission isn’t speaking to the media, and the government has yet to utter the word “casino” in public.
For now, the UAE’s future as a global gambling hub is a story unfolding quietly, in the shadows.
What We Do Know:
While rumors of gaming have flown around the UAE for years, the casino industry started taking shape in January 2022.
That’s when Wynn Resorts announced a partnership with the fourth largest of the seven UAE emirates, Ras Al Khaimah (RAK), to develop a large-scale resort.
- In January 2022, Ras Al Khaimah announced an “integrated resort” with Wynn Resorts, set to open in 2027, mentioning a “gaming area” without using the word “casino.” Later that month, Ras Al Khaimah created the Department of Entertainment and Gaming Regulation to oversee integrated resorts and gaming.
- In November 2022, Wynn Resorts CEO Craig Billings confirmed plans for a “casino component” in the resort, possibly the first time the word had been publicly used in reference to a project in the region.
- In August 2023, Billings told investors he expected a RAK casino license “imminently,” and that “there should be no concern that there is a legalization process that needs to occur in order for gaming to occur in that property.” [As of October 2024, there has been no public confirmation that it’s been granted.]
- In September 2023, the UAE established the General Commercial Gaming Regulatory Authority (GCGRA). That same month, MGM Resorts CEO Bill Hornbuckle mentioned a “gaming decree” in the UAE during a talk at the Bank of America Gaming and Lodging Conference, saying: “Reportedly there’s a gaming decree that has been signed, but not released.” He also said he anticipated four casino licenses to be granted.
- In July 2024, without a press release, the GCGRA launched its website with information for operators who would apply for a gaming license. No operator confirmed applying for a license.
- In September 2024, MGM Resorts confirmed it had applied for a casino license in Abu Dhabi, becoming the first operator to do so.
- On October 4, 2024, Wynn Resorts issued a press release saying it had received a “Commercial Gaming Facility Operator” license from the GCGRA, providing no other details. It is scheduled to give an update to analysts and investors on October 8 about its UAE project.
Representatives from Dubai Tourism and the Abu Dhabi Department of Culture and Tourism did not respond to a request for comment. Ras Al Khaimah Tourism Development Authority declined to comment on gaming in the emirate.
The ‘Wynn Effect’
In terms of tourism, Ras Al Khaimah has long been overshadowed by its larger and glitzier neighbors, Dubai and the UAE’s capital, Abu Dhabi. But that may be about to change. The emirate is betting big on a massive Wynn Resorts property planned for Al Marjan Island, a man-made archipelago off RAK’s coast.
The ambitious $3.9 billion project, slated to open in the coming years, will feature over 1,500 rooms, 24 restaurants, and what could become one of the most talked-about casinos in the region. Wynn Resorts is putting in $900 million for its 40% stake in the venture, with much of the remainder publicly financed by the Ras Al Khaimah government. However, this level of investment won’t come without challenges. A May 2023 report from Fitch Ratings warned that the project would “weigh on public finances initially.”
Wynn declined to comment on the status of the project.
According to a prospectus detailing the project, Wynn estimates that adjusted EBITDA for the resort could reach up to $600 million a year. By comparison, the long-standing Wynn Las Vegas had an adjusted EBITDA of $801 million in 2022.
The prospectus states the casino part of the hotel will be 224,000 square feet – that’s almost 10,000 square feet larger than the casino floors of Wynn Las Vegas. If you need help visualizing its size, picture two football pitches or two city blocks and you’ll be close.
Wynn has even trademarked the names “Arabian Strip” and “Marjan Strip,” hinting at future development on the island. It has also previously stated it would be open to operating other hotels in the area. “We and our partners are in active discussions around those adjacent parcels [of land] and I expect additional hotels will act as a powerful feeder to Wynn Al Marjan Island,” Billings said in an April 2023 webcast.
Wynn Resorts recently snapped up 70 more acres of land in RAK for development and has been beefing up its team in RAK with executives from Las Vegas.
MGM in Dubai
MGM Resorts also has a project in the country but it isn’t as far along. It announced a Dubai project in 2017, envisioning an MGM, Bellagio, and an Aria hotel sitting on a man-made island – but there is no scheduled opening date and the project remains in limbo.
MGM Resorts told investors in February the project will cost around $2 billion. Notably, that is without plans for a casino.
Meanwhile, the company is looking toward Abu Dhabi for its casino ambitions. Though there are no active projects in the capital, MGM has expressed interest in securing a gaming license there.
CEO Hornbuckle confirmed at the Skift Global Forum 2024 in September that the company had applied for a gaming license.
“Yes, we have [applied]. We’ve done it in Abu Dhabi,” said Hornbuckle. “The way it will work is the federal government in Abu Dhabi will approve it, we’ve applied for it and hopefully we’ll win the license there. Each ruler has their city, their state. Each can say yes or no.”
Hornbuckle added that he hopes to gain clarity on the federal mandate by the end of this year.
His comments reflect MGM’s cautious optimism after a previous attempt to enter the Abu Dhabi market without a casino. In 2006, MGM announced plans for a non-gaming project in Abu Dhabi, which never got off the ground. Hornbuckle said he would not go into Abu Dhabi again without a casino license, since “that’s the business MGM is in.”
MGM declined Skift’s request for comment.
The Rules of the Game
In July, the UAE’s federal entity for gaming – the General Commercial Gaming Regulatory Authority (GCGRA) – announced it was accepting proposals for gaming licenses. As part of this move, the GCGRA also published regulations detailing how businesses can build and operate casinos.
According to the GCGRA’s website: “Commercial Gaming refers to 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.”
GCGRA will regulate lotteries, internet gaming, sports wagering, and land-based gaming facilities. Regulated games at those facilities would include slots, roulette, blackjack, baccarat, craps, and more, according to GCGRA’s website.
The GCGRA’s board of directors is chaired by Jim Murren, who was the chairman and CEO of MGM Resorts from 2008 to 2020. Notably, Murren is not on the selection committee for handing out gaming licenses.
To qualify for a gaming license, operators must have a “qualifying domestic entity,” or QDE, in the UAE or have a relationship with one. This QDE must have a “substantial” financial and operational history in the country.
Both Wynn and MGM have QDEs in the form of local developers.
John DeCree, director of equity research at CBRE, highlighted the importance of these partnerships to Skift, stating, “I look at Wynn and the partnership with them in Marjan [the local developers] and RAK as a good template: It keeps majority ownership with a local entity. It all supports the view that the majority of business will be for domestic companies.”
The GCGRA did not respond to Skift’s request for comment.
Other Hotels: FIVE, Atlantis, and Venetian?
Las Vegas Sands in August filed a trademark for “Venetian” for use in the UAE. Las Vegas Sands did not respond to Skift’s request for comment on this.
Local hotel group FIVE has said it is not currently pursuing casinos. “We’re a place where we make money while customers leave happy. Casinos are the only places where you make money while customers leave unhappy. I’m not sure whether FIVE is well-suited for that,” said FIVE chairman Kabir Mulchandani, responding to a question from Skift in his most recent earnings call.
“In terms of gaming, it is not a priority for us. We would do it in response to a competitive environment. We would not actively pursue gaming ourselves. If we were to do it, we would not operate [the] casino, we would bring a casino operator in. It doesn’t align with our ESG principles, so it is not something to actively pursue, we would only pursue it if it was necessary to maintain the rest of the business.”
Other operators have remained quiet on whether they have applied for a casino license. DeCree, who is based in New York City and recently visited UAE, thinks one candidate is Atlantis.
Atlantis Dubai is split into two resorts next to each other: Atlantis, The Palm opened in 2008 and Atlantis, The Royal opened in 2023. Atlantis Dubai does not have gaming, but the brand was founded with a casino resort in the Bahamas, and the two Dubai properties retain an integrated resort feel.
“Our conversations during the trip lead us to believe that Atlantis The Royal was designed and built with gaming in mind should gaming be legalized and the project obtain a license,” DeCree wrote in his report on the UAE gaming industry.
In August, Atlantis Dubai named Paul Baker as its new president. Baker was previously president of the Grand Lisboa Palace in Macau, a $5 billion resort with close to 1,900 rooms, 300 game tables, and 1,150 slot machines. He has close to two decades of experience in the integrated resort industry and spent a year as executive vice president of Wynn Macau, and five years as vice president of Caesars Palace in Las Vegas.
Atlantis declined to comment on whether it would operate a casino in Dubai, saying: “We have nothing to add at this time.”
Market Size
CBRE estimates the gross addressable market of casinos in the UAE at upwards of $8.5 billion. This would suggest the UAE casino market would be similar in size to the Las Vegas Strip and 50%-70% larger than Singapore’s current casino industry.
CBRE’s estimate assumes a “reasonably penetrated market with sufficient gaming supply.” However, it is suspected the market will likely remain supply-constrained initially with two or three casinos, possibly limiting the full potential of the market.
Is the Culture Ready?
Building the world’s next Las Vegas will take more than installing a lot of slot machines and allowing sports betting. There needs to be a fundamental culture shift.
Hornbuckle said this month that he believes the UAE is already over that cultural hurdle.
“Look, there’s a cultural barrier to get through but that has now happened. Once you get there and gaming is socially accepted – not for Emiratis by the way – but 80-90% of the [UAE] population are non-Emirati. India is a massive market, the rest of the Middle East could be massive, China will continue to come to Dubai, so we’re excited by what it presents and we hope to be there.”
Along with a culture change, there needs to be an understanding that what makes Las Vegas so alluring isn’t just the gambling, it’s the world-class entertainment industry, and more recently, sports.
Steve Hill, CEO and president of the Las Vegas Convention and Visitors Authority said this month at Skift Global Forum 2024: “Sports has meant a lot to Las Vegas. It has been the next step in the city’s evolution…Formula 1 and the Super Bowl in particular have opened up the eyes of the world to Las Vegas. That creates critical mass and interest, they see the success [of those events] and they call us.”
Like Vegas, the UAE is big on sports. Abu Dhabi has its own Formula 1 track and is hosting UFC games more and more. Last year, the city had the Abu Dhabi Showdown Week UFC 294, the 2023 FIBRA Men’s World Cup, and NBA Abu Dhabi Games 2023.
MGM is even creating its own “Sphere” in Dubai, though not currently backed by Sphere Entertainment.
Hornbuckle said at the Skift Global Forum that it will be “equally compelling as the Las Vegas Sphere.”
“It’ll have a show line that walks through the history of Dubai. The first time I went, I thought [Dubai] was Las Vegas on steroids,” said Hornbuckle. “In 1985 it was desert and literally 35 years later it’s this ‘megatropolis’ with three million people. We’re going to tell that story.”
We don’t know yet exactly what the UAE casino sector will look like, but we know it’s going to be big. It seems the country has already started to accept they are coming, and the UAE is mirroring many of the practices we saw in Las Vegas over the years.
One thing is clear: the world’s newest gambling hub is emerging from the sands of the Middle East, and it’s going to make waves. So let’s talk about it.
