Asia & Middle East · AE
United Arab Emirates
A fast-developing financial centre with licensing routes onshore, at emirate level and within the financial free zones, under several regulatory authorities.
At a glance
- Status
- Federation of seven emirates
- Region
- Asia & Middle East
- Regulated sectors
- GamingPaymentsCryptoInvestment
- Authorities
- VARA · FSRA · DFSA · Central Bank of the UAE · General Commercial Gaming Regulatory Authority
- Licensing routes
- 4
- See also
- Dubai / VARA
Overview
The framework
In the UAE, the regulator depends on where a business is established and what it does, so choosing a location also means choosing a framework. Virtual asset activities in Dubai (outside the DIFC) are regulated by VARA, while the financial free zones ADGM and DIFC have their own regulators and legal frameworks.
Onshore payment services and stored value facilities fall under the Central Bank of the UAE. A federal regulatory authority for commercial gaming was established in 2023, opening a separately regulated field. We help you choose the zone and prepare the filing.
Authorities
Who regulates what
- Virtual Assets Regulatory Authority (VARA)
- Virtual asset activities in Dubai, outside the DIFC.
- ADGM Financial Services Regulatory Authority
- Financial services and virtual assets within ADGM.
- Dubai Financial Services Authority (DFSA)
- Financial services within the DIFC.
- Central Bank of the UAE
- Onshore payments, stored value facilities and banking.
- General Commercial Gaming Regulatory Authority
- Federal commercial gaming regulation.
Regimes
Licensing routes
VARA licence
Activity-based licences for virtual asset service providers in Dubai.
Sectors: Crypto
ADGM / DIFC authorisation
Financial services permissions within the financial free zones.
Sectors: Crypto · Investment · Payments
Payment / SVF licensing
Central Bank licensing for retail payment services and stored value facilities.
Sectors: Payments
Commercial gaming licence
Federal licensing of commercial gaming, including lotteries and internet gaming.
Sectors: Gaming
Our Regulatory & Licensing practice prepares the applications for these routes and manages them through to the regulator's decision.
Considerations
What to weigh up
- Choose the zone first: it determines the regulator, legal system and client reach.
- Plan local substance, an office and resident management; all are expected.
- Plan a specific analysis of any gaming activity under the federal framework.
This overview is general information, summarised at a high level. Requirements change and depend on the specific activity; seek advice on your circumstances before acting.
Industries
Relevant industries
- iGaming & GamingB2C operators, B2B suppliers, platforms, aggregators and affiliates.
- Fintech & PaymentsPayment and e-money institutions, PSPs and acquirers, payment facilitators and embedded finance.
- Crypto & Digital AssetsCASPs and VASPs, exchanges, custodians, wallets, token projects and crypto payments.
- Forex & InvestmentsForex and CFD brokers, investment firms, trading and investment platforms.
Across jurisdictions
Cross-jurisdiction capabilities
Services we support across the jurisdictions in our directory, described once on their own pages. We deliver each to the requirements that apply locally, coordinating local specialists where local law, registration, representation or professional requirements require it.
- Privacy & Data ProtectionExternal DPO services and working privacy programmes: GDPR and global privacy laws, DPIAs, data mapping, transfers and ISO/IEC 27701.
- Information Security & CybersecurityFractional CISO support, ISMS and security programmes, certification and audit readiness, DORA, NIS2 and customer assurance for enterprise sales.
- AI GovernanceGovernance that lets AI adoption scale: EU AI Act readiness, ISO/IEC 42001 management systems, AI risk and impact assessments, and vendor risk.
- AML & Financial Crime ComplianceAML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.
- IP Registration & ProtectionTrademark and patent registration, copyright, domain disputes and enforcement that protect your brand, software and content across markets.
- Legal OpinionsRegulatory, business model, perimeter, payment, gaming, crypto-asset and cross-border opinions that answer what banks and investors ask.
- Bank Account OpeningHelp organising your banking with banks and EMIs that fit your model, from the onboarding file and account structure to periodic reviews.
- Merchant Account / Acquiring SetupMerchant applications, acquiring structure and negotiated terms for online and high-risk merchants that need stable card and local payment acceptance.
Support
United Arab Emirates: how we support your business
- Regulatory & LicensingStrategy, applications and regulator engagement for the gaming, payments, crypto and investment routes listed above.
- Corporate StructuringGroup architecture, incorporation, substance and governance built around your licences, banking and investors.
- Market Entry & Regulatory StrategyMarket prioritisation, regulatory roadmaps and launch readiness that let you expand into new jurisdictions in the right order.
United Arab Emirates: the right fit for your business?
We look at your product, target clients and banking needs to see whether this jurisdiction fits or another would serve you better, then send a written proposal with scope, timetable and fee.