Asia & Middle East · AE
United Arab Emirates
A fast-developing financial centre with several regulatory authorities — onshore, emirate-level and within the financial free zones.
At a glance
- Status
- Federation of seven emirates
- Region
- Asia & Middle East
- Regulated sectors
- PaymentsCryptoInvestment
- Authorities
- VARA · FSRA · DFSA · Central Bank of the UAE · General Commercial Gaming Regulatory Authority
- Licensing routes
- 3
- See also
- Dubai / VARA
Overview
The framework
The UAE's regulatory landscape depends on where the business is established and what it does. 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.
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
Applications and regulator engagement for these routes are handled by our Regulatory & Licensing practice.
Considerations
What to weigh up
- The choice of zone determines the regulator, legal system and client reach.
- Local substance, office and resident management are expected.
- Gaming activity requires specific analysis 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. How each is delivered depends on the local requirements that apply; where local qualification is required, we coordinate locally qualified counsel.
- Privacy & Data ProtectionPrivacy compliance and GDPR programmes, notices and DPAs, DPIAs, data mapping and ROPA, transfers, audits and breach response.
- 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 and protection, copyright protection, domain name disputes, portfolio support and IP agreements.
- Legal OpinionsRegulatory, business model, perimeter, payment, gaming, crypto-asset and cross-border opinions for banks, partners and investors.
- Bank Account OpeningSupport with corporate and operational accounts at banks and EMIs, prepared for how their compliance teams assess high-risk businesses.
- Merchant Account / Acquiring SetupSupport with merchant account applications and acquiring setup at acquirers and PSPs, including for high-risk merchant categories.
Support
How we support businesses in United Arab Emirates
- Regulatory & Licensing01Strategy, applications and regulator engagement for the payments, crypto and investment routes listed above.
- Corporate Structuring02Group architecture, incorporation, substance and governance built around your licences, banking and investors.
- Market Entry & Regulatory Strategy10Market prioritisation, regulatory roadmaps and launch readiness for businesses expanding into new jurisdictions.
Discuss your matter with a senior advisor.
Share a few details about your business and plans. We will come back to arrange a confidential initial conversation.