United Arab Emirates – CM CO

2025, Cross-border, Update

Country Manual Cryptos Overview Update

United Arab Emirates

BRP has updated its Country Manuals Cryptos Overview for

United Arab Emirates

out of Crypto-Asset service provider’s country of establishment (DEF, RS & RT)

SOURCE OF CHANGESANSWERS
  Law/Regulation  No
  New Position of the Authorities  No
  Evolution of Expert’s interpretation  Yes

Definitions & Concepts, Regulatory Summary and Behaviour Template

The Country Manual Cryptos Overview has been reviewed to ensure that the content of all the documents remain accurate and up to date.

A new law regulating banking activities in the UAE was issued on 8 September 2025. Federal Decree-Law No. (6) of 2025 regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business (the “New Banking Law”) became effective on 16 September 2025. The said law repeals and replaces the old Banking Law, Decretal Federal Law No. 14 of 2018 regarding the Central Bank and Organization of Financial Institutions and Activities (the “Law of 2018”). 

The New Banking Law consolidates prudential and conduct supervision of banks and other financial institutions under the CBUAE and expands the CBUAE’s regulatory perimeter to capture technology service providers that facilitate financial services. The inclusion of providing payment services using virtual assets as a licensable activity follows the adoption of the Payment Token Services Regulation in June 2024 (the PTS Regulation), which sets out the revised regulatory framework for the provision of ‘payment token services’ in the UAE. 

Existing regulations, decisions, standards, guidelines and circulars issued under the Central Bank Law remain in force until expressly replaced.

Material changes

In line with the regulatory changes outlined above, the Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date.

Non-material changes

Some comments and content have been slightly 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 11th 2025