Virtual assets
Four regimes, and the gaps between them.
An emirate-level regime, two free-zone ones and a federal regime for payment tokens. Where a business sits decides which of them it answers to.
What makes this sector hard
- Definitions that do not align across the four regimes
- Payment tokens caught by the federal regime rather than the virtual asset one
- Marketing rules that apply before any licence is held
- Custody, segregation and proof-of-reserve expectations
The UAE is one of the few places with a purpose-built virtual asset regime in more than one jurisdiction. That is an advantage and a trap: the definitions do not line up, and an activity licensed in one place may be unlicensed conduct a few kilometres away.
The council maps the activity against all four regimes before anyone talks about an application.
Where it applies
Where to start
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Entering the UAE market
Onshore or a financial free zone — and what each one costs you.
The UAE is not one jurisdiction. Choosing between the mainland and a financial free zone sets your licensing route, your courts, your data rules and your tax position for years.
Learn more Entering the UAE market -
Licensing and authorisation
What you need permission for, and from whom.
Regulated activity in the UAE is defined narrowly and enforced literally. The expensive mistakes are the ones where a firm thought it was outside the perimeter.
Learn more Licensing and authorisation -
Building a compliance programme
Policies that survive an inspection.
AML/CFT, sanctions, data protection and conduct — drafted against the instruments that actually apply to you, not a template from another market.
Learn more Building a compliance programme
Other sectors
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Najem AI produces analysis and drafts for internal use. It is not legal, tax, audit or investment advice and does not create a professional relationship.