Country Manual Cryptos Overview Update
Dubai IFC

BRP has updated its Country Manuals Cryptos Overview for
Dubai IFC
out of Crypto-Asset service provider’s country of establishment (DEF, RS & RT)
| SOURCE OF CHANGES | ANSWERS |
|---|---|
| Law/Regulation | Yes |
| New Position of the Authorities | No |
| Evolution of Expert’s interpretation | No |
Definitions & Concepts, Regulatory Summary and Behaviour Template
Regulatory changes
The Cryptos Overview has been reviewed to ensure that the content of all the documents remain accurate and up to date.
On 15 December 2025, the Dubai Financial Services Authority (DFSA) published amendments to its policy statement on FiatCrypto Tokens and its Supervisory Guidelines on the assessment of Crypto Tokens. The amendments enter into force on 12 January 2026.
Under the previous regime, firms could provide financial services within or from the DIFC only in connection with Recognised Crypto Tokens (i.e. tokens formally approved by the DFSA and listed on its website), subject to limited exceptions such as certain custody services.
Under the revised framework, the DFSA has removed the general recognition requirement for Crypto Tokens. Firms engaging in activities involving a Crypto Token (other than a Fiat Crypto Token) must now conduct and document their own suitability assessment for the relevant token in relation to the specific activity. A transitional period applies whereby previously recognised Crypto Tokens (other than Fiat Crypto Tokens) will continue to be deemed suitable for three months following the entry into force of the new rules.
Fiat Crypto Tokens remain subject to a centralised DFSA suitability assessment. The DFSA has published both the assessment criteria and a list of Fiat Crypto Tokens currently considered suitable for use in the DIFC, namely Circle Euro Coin (EURC), Circle USD Coin (USDC) and Ripple USD (RLUSD).
Material changes
There are no material changes that affect the answers in the Cryptos Overview Behaviour Template.
Non-material changes
Some comments and content have been reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.
For more information, please contact us: info@brpsa.com
Geneva, December 18th 2025