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m&a deal advisory

M&A Deal Advisory in the UAE: Evaluating Risks and Opportunities Before You Buy

Introduction

Most M&A deals in the UAE unravel after the ink dries—not because of valuation mistakes, but due to overlooked compliance and integration hurdles. Licensing mismatches, hidden Ultimate Beneficial Ownership (UBO) complexities, and anti-money laundering (AML) gaps can freeze accounts or void approvals. Regulatory layers such as UBO disclosures and AML checks often go unnoticed—leading to compliance breakdowns or license issues post-acquisition.

Before you buy, risk assessment must drive every step of your transaction advisory services. You need clarity on how the target company’s licenses align with your business model, whether existing staff visas remain valid post-acquisition, and if the entity complies with the Ministry of Economy’s UBO guidelines.

That’s why smart buyers seeking M&A deal advisory rely on HLS-Global UAE—we build a risk-first strategy so you avoid surprises, secure your investment, and ensure your new venture is regulator- and bank-ready from day one.

The New Regulatory Terrain for M&A Deals

The UAE’s regulatory landscape for mergers and acquisitions has evolved dramatically. Gone are the days when financial valuation alone sealed a deal. Today, buyers must navigate complex compliance layers—especially around Anti-Money Laundering (AML) and Ultimate Beneficial Ownership (UBO) disclosures. The Ministry of Economy has intensified scrutiny on UBO filings, making incomplete or inaccurate declarations a direct trigger for fines, frozen licenses, or even forced business closures.

Many buyers underestimate these compliance layers during M&A negotiations. Overlooking regulatory obligations can lead to unexpected compliance issues, stalled operations, or penalties, while ignoring AML red flags can derail banking relationships post-acquisition. This is why transaction advisory services should include a regulatory audit, not just a financial one. At HLS-Global UAE, our M&A deal advisory team aligns deal structures with current laws, ensuring your acquisition stands up to regulatory review—and preserves operational continuity long after the ink dries.

Hidden Liabilities: What Due Diligence Must Cover in 2025

Hidden liabilities often determine whether your M&A deal becomes an asset or a liability. In the UAE, due diligence must go far beyond reviewing balance sheets. You need a deep dive into operational licenses—are they valid, transferable, and compliant with UAE mainland or free zone rules? Tax exposure is another overlooked trap: Unresolved VAT filings, UBO mismatches, or compliance errors can surface after you close. Staff visas and labor contracts must match the acquired entity’s stated headcount and salary obligations—misalignment can trigger Ministry of Human Resources audits. Hidden legal disputes with suppliers, landlords, or regulators can escalate quickly post-acquisition.

At HLS-Global UAE, we use our M&A deal advisory experience to lead comprehensive compliance-focused due diligence. Our transaction advisory services identify risks that could freeze accounts or void licenses, ensuring your deal survives beyond signing and aligns with evolving UAE regulations. Talk to us before you buy.

Structuring the Acquisition: Mainland vs. Free Zone Considerations

Most M&A buyers underestimate how a UAE target’s location—mainland or free zone—shapes the deal’s success. In mainland acquisitions, licenses are linked to physical premises and may not transfer without reapplication, triggering delays or rejections if not planned. In free zones, licenses can be even more restrictive: some require shareholders to requalify with the authority, adding hidden costs and time.

Bank relationships also vary—many mainland accounts rely on local sponsorship documents, which dissolve in ownership changes. Free zone accounts may close automatically if the zone authority isn’t updated before the acquisition. Contract enforceability shifts too; agreements drafted under mainland jurisdiction might not carry over to free zone entities, exposing buyers to disputes they can’t win.

At HLS-Global UAE, our transaction advisory services and M&A deal advisory experts map these risks before you sign, ensuring your deal structure aligns with licensing, banking, and legal realities, not assumptions.

Integration Risks That Break Deals After Signing

Most M&A failures in the UAE don’t happen during negotiations—they happen right after the deal closes. Buyers assume inherited staff, supplier contracts, and daily operations will transfer smoothly. But unclear employment terms, expired vendor agreements, or licensing mismatches can cause immediate disruptions. You risk losing key talent if employment benefits, visas, or titles aren’t aligned with the new owner’s structure. Vendors may suspend services if contract reassignments aren’t negotiated upfront, stalling operations from day one.

Early integration planning is essential. At HLS-Global UAE, we embed HR assessments, contract reviews, and licensing verifications into our M&A deal advisory process. This ensures operational continuity, preserves employee morale, and maintains supplier trust. With our transaction advisory services, you can confidently acquire businesses knowing your integration strategy will protect revenue, secure assets, and avoid operational chaos that turns a promising deal into a costly liability. Ready to secure your acquisition’s success?

When HLS-Global UAE Steps In

Before you commit to an acquisition, HLS-Global UAE steps in to uncover what numbers alone can’t show. Our M&A deal advisory team stress-tests your target’s licensing, corporate structure, and UBO records to ensure the deal won’t collapse under regulatory scrutiny. We’ve helped buyers avoid last-minute license rejections by revealing outdated trade activities, uncovering hidden tax liabilities that would have triggered fines, and clarifying ownership chains to satisfy AML and UBO compliance requirements.

Our transaction advisory services go beyond standard financial due diligence—we coordinate with banks to confirm post-acquisition account viability and align the acquisition structure with the UAE’s compliance frameworks. This approach makes your deal regulator-ready and bank-compliant from day one, preserving your investment and credibility.

For a transaction that withstands the UAE’s complex rules, talk to HLS-Global UAE before you sign. Let our experts secure your M&A success with precision and foresight.

Final Word: Buy with Clarity, Not Assumptions

Most M&A failures in the UAE aren’t due to poor valuations—they happen because buyers overlook regulatory red flags, hidden tax exposures, or licensing complications unique to the region. In today’s environment, Regulators enforce Ultimate Beneficial Ownership rules strictly, along with broader compliance expectations in M&A transactions. Missed details can freeze bank accounts or invalidate licenses post-acquisition. At HLS-Global UAE, we don’t just crunch numbers; we dig into your target’s compliance posture, banking relationships, and operational realities so you avoid nasty surprises. Our M&A deal advisory team helps you map real risks before you commit capital, while our transaction advisory services ensure smooth license transitions, risk analysis, and regulatory coordination with relevant UAE authorities. Don’t let assumptions sink your investment.

Talk to HLS-Global UAE today—buy with clarity, not blind spots. Get the guidance that protects your deal, your reputation, and your future growth in the UAE.

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UAE residence visa UAE working visa

Working in the United Arab Emirates : Residence Visa Regime

  • As the UAE cements its status as a global nexus for talent, innovation, and investment, understanding its multi-tiered residence visa framework is essential. Whether you’re an employee, entrepreneur, investor, freelancer, or sponsor, this guide distills the core requirements, procedures, and timelines—plus how HLS-Global UAE ensures a seamless journey from application to stamping.

1. Green Visa for Work (5 Year, Self-Sponsored)

🔎What It Is

A long-term, self-sponsored residence visa valid for five years allows skilled employees, freelancers and self-employed individuals to live, work and sponsor family—without an employer or national guarantor.

✅Who Qualifies & Key Requirements

Freelancers & Self-Employed

  • Valid freelance/self-employment permit from MOHRE (Ministry of Human Resources & Emiratisation), For guidance on establishing your business structure, see our UAE Market Entry and Restructuring Support services.
  • Bachelor’s degree or specialized diploma.
  • Minimum AED 360,000 annual income over the past two years or proof of financial solvency for the duration of stay.

Skilled Employees

  • Active employment contract in the UAE.
  • Bachelor’s degree or equivalent.
  • Minimum salary of AED 15,000 per month.
  • Classified at first, second or third occupational level by MOHRE.

(Note: The applicable occupational levels are as follows- Level 1: Legislators, managers, and business executives; Level 2: Professionals in scientific, technical and human fields; Level 3: Technicians in scientific, technical and humanitarian fields)

📩Key Advantages
  • 5-year renewable term.
  • No sponsor dependency; self-sponsorship.
  • Can sponsor spouse, children, and other family members.

Understanding compliance requirements is essential – learn more about Regulatory Compliance Services.

📆Process & Timeline

Self-application digitally via MOHRE/GDRFA e-portal service; processing generally completes within 4–6 weeks.

2. Standard Work Visa (2 Year, Employer-Sponsored)

🔎What It Is

The traditional employment visa for private-sector, government and free-zone employees—valid for up to two years and fully sponsored by the hiring entity.

✅Who Qualifies & Key Requirements
  • Private-sector (commercial, industrial, professional); government employees; free-zone personnel (e.g., DIFC, DMCC).
  • Signed employment contract and valid company trade license, Companies establishing operations in UAE should review our Starting a Consultancy in Dubai guide for licensing requirements.
  • Passport copy (≥6-month validity) plus passport-size photos.
  • Attested academic/professional certificates (where specified).
📆Process & Timeline
  • Employer Applies via MOHRE/GDRFA e-portal followed by medical examination at an approved health center, Emirates ID enrollment with ICP, and finally Visa stamping on the passport at GDRFA/MOI (Ministry of Interior).
  • Processing generally completes within 3–5 weeks.

3. Golden Visa (10 Years, No Sponsor Required)

🔎What It Is

A long-term residency visa (10 years) designed to attract high-value investors, entrepreneurs, specialists, scientists, creatives, outstanding students, humanitarian pioneers and frontline heroes.

📩Key Advantages
  • 6-month multiple-entry permit to initiate residency.
  • 10-year renewable residence; no sponsor required.
  • Extended absence allowance (beyond the standard 6 months).
  • Unlimited family & domestic-helper sponsorship.
  • Family stay assured even if the primary holder passes away.
✅Key Eligibility Categories & Requirements

Investors in Public Funds

  • AED 2 million deposit in an accredited UAE fund or AED 2 million share capital in a company.
  • Annual FTA (Federal Tax Authority) tax payment ≥ AED 250,000.
  • 100% ownership of invested capital and proof of medical insurance.

Real-Estate Investors

  • Property portfolio ≥ AED 2 million (owned outright or via approved local-bank loan).

Entrepreneurs

  • Economic project of a technical/innovative nature valued ≥ AED 500,000.
  • Our Advisory Services team can help evaluate project feasibility and structure innovative ventures.
  • Approvals from a UAE auditor, relevant emirate authority and an accredited incubator.

Outstanding Specialized Talents

  • Doctors, scientists, inventors, artists, executives, athletes, PhD holders, and engineers.
  • Category-specific recommendation letters from ministries, councils or accredited bodies.

Outstanding Students

  • National high-school toppers (≥ 95%) or university graduates (GPA ≥ 3.5–3.8; top 100 global universities).
  • Recommendation from Ministry of Education/university; graduation within two years.

Humanitarian Pioneers & Frontline Heroes

  • Minimum five years of distinguished service or funding ≥ AED 2 million; recommendation by competent authorities.
📆Process & Timeline
  • Via ICP “One Touch” service: digital submission, multi-step consolidation of entry permit, residency, Emirates ID and renewals in one workflow.
  • Processing generally completes within 4–6 weeks.

How HLS-Global UAE Streamlines Your Visa Journey

  1. Personalized Category Selection

We analyze your profile—employment, investment, talent—to recommend optimal visa type and jurisdiction.

  1. End-to-End Project Management

From document attestation and application drafting to regulatory follow-up, we handle every detail.

  1. Fast-Track Liaison

Leveraging our direct channels with MOHRE, GDRFA, ICP, and free zones for priority processing.

  1. Compliance & Renewal Alerts

Automated calendar reminders, audit preparations, and proactive renewals to keep you visa-ready.

The UAE’s recent removal from the EU’s high-risk countries list further strengthens its appeal for international residents and investors.

 Ready to secure your UAE residency with zero hassle?

Contact HLS-Global UAE at info@hls-global.ae or visit www.hls-global.ae for a complimentary eligibility assessment.

Navigate the Emirates confidently—your new chapter starts here.

 

Disclaimer: All views expressed in this article are solely for informational purposes and should not be construed as legal advice. This information is for reference only and is bound to change in case of any amendments or changes to applicable laws. We do not assume any responsibility or liability for any errors or omissions in the content of this article, and do not make any warranties about the completeness, reliability and accuracy of the information expressed in this article.

Commercial gaming

Commercial Gaming & Gambling in the UAE Regulatory Framework

Over the past year, the United Arab Emirates has taken unprecedented steps to regulate commercial gaming (casinos, lotteries, sports betting, etc.), aiming to unlock tourism and economic growth. In 2023, the federal government created the General Commercial Gaming Regulatory Authority (GCGRA) to oversee all licensed gambling under strict, globally-aligned standards. Any company or individual looking to offer casino-style gaming, online betting, lottery or related activities must now obtain a GCGRA license. Our regulatory compliance services help navigate these complex licensing requirements. At HLS-Global UAE, we have been closely monitoring these developments and stand ready to guide clients through the licensing and compliance requirements in this evolving sector.

1. Regulatory Framework & Market Outlook

For decades, most forms of gambling were prohibited in the UAE aside from limited charitable raffles and small promotional lottery draws. In late 2023, the UAE announced a shift: it established the GCGRA and introduced a comprehensive licensing regime. Under the new rules, all commercial gaming requires licensing by the federal authority. Operating without a license is illegal and carries severe penalties (heavy fines, imprisonment, and business closure). Proper business setup in the UAE is essential before pursuing gaming licenses. The GCGRA’s mandate now covers lotteries, internet gaming, sports wagering and land-based facilities (casinos, slot halls, etc.).

The UAE’s new gaming regime is already in motion. In July 2024, the GCGRA awarded the first national lottery license to The Game LLC (an Abu Dhabi-based company). Existing raffle operators (Emirates Draw and Mahzooz) paused their draws at the GCGRA’s request during the licensing process. In October 2024, Wynn Resorts announced it had received the UAE’s first casino license for its planned $3.9 billion resort on Ras Al Khaimah’s Al Marjan Island. These landmark developments have set the stage for further expansion of licensed gaming in the UAE.

The Wynn Al Marjan resort (RAK) is slated to open mid-decade as the UAE’s first luxury casino destination. Abu Dhabi and Dubai have not publicly announced specific casino projects yet, but both emirates are actively designing entertainment zones and regulations. Online gaming and sports betting platforms (including international operators) are also expected to seek UAE licenses as the framework matures. Overall, the outlook for commercial gaming in the UAE is cautiously optimistic. The regulatory framework provides clarity for investors while balancing cultural and social concerns. As additional licenses are issued and projects are built, the UAE could emerge as a major regional gaming hub.

2. Who Needs a License (Eligible Parties)

The UAE’s GCGRA regulates all commercial gaming activities (lotteries, casinos, online betting, sports wagering, etc.) at the federal level. Any company or individual engaging in such activities must obtain the appropriate GCGRA license before operating. Our UAE market entry and restructuring support guides international operators through market entry requirements. The licenses are broadly divided into entity licenses and individual licenses, each with detailed documentary and suitability requirements as below:

  • Gaming Operators: Any company that runs gambling activities must be licensed. This includes casino operators, lottery organizers and retailers, online gaming platforms, sports and event betting operators, etc.
  • Gaming Vendors: Suppliers of gaming equipment or services (e.g. makers of slot machines, IT platforms) must obtain a vendor license.
  • Key Corporate Persons: Entities or individuals controlling a gaming business (typically ≥15% ownership or voting control) must be licensed as Key Persons (Corporate).
  • Key Individuals & Employees: Senior personnel – such as CEOs, CFOs, board members or other “key persons” – and any gaming employees (dealers, attendants) require individual licenses or occupational permits.

Each license type has specific criteria, but broadly any person or company whose activities fall under the definition of commercial gaming must obtain the appropriate GCGRA license before operating. Under GCGRA regulations, “commercial gaming” refers to any activity in which money (or its equivalent) is wagered on games of chance or skill—covering lotteries, casinos, online betting, sports/event wagering, and related gaming platforms.

3. Licensing Process (Key Steps)

The GCGRA’s licensing process is structured and thorough. The key steps are as below:

  1. Intake & Screening: Submit an Intake Form to notify the GCGRA of your intent and provide basic company and project details. The GCGRA performs an initial eligibility review.
  2. Portal Access & Application Fee: If pre-screening is passed, the applicant pays a non-refundable application fee to gain access to the GCGRA’s online licensing portal. All detailed application materials are then submitted through this portal.
  3. Document Submission: Provide comprehensive documentation via the portal – including corporate records, financial statements, organization charts, business plan, information on key persons and third parties, and a responsible gaming plan.
  4. In-Principle Approval: The GCGRA reviews the submission and, if all requirements are met, grants an in-principle approval. At this stage, the applicant pays an ‘In-Principle Fee’ equal to 10% of the total license fees. This approval allows the applicant to incorporate entities, obtain permits, and open bank accounts in preparation for operations.
  5. Final Review & License Issuance: After fulfilling any remaining conditions (such as finalizing corporate structure or technology readiness), the applicant pays the remainder of the license fee (the other 90%). Upon receipt of all fees and documentation, the GCGRA issues the final commercial gaming license and a ‘Certificate of Operation’.

Throughout this process, the GCGRA conducts thorough suitability checks (integrity, financial soundness, criminal background, etc.) on all owners, investors, and key personnel. While the GCGRA aims for an expeditious review, it has not published a fixed timeline. In practice, applicants should allow several months from initial intake to final approval, depending on application completeness and regulatory workload.

4. Fees & Timeline

  • Application Fee: Paid upfront to access the licensing portal. It covers preliminary review and is non-refundable. (The exact AED amount has not been publicly disclosed.)
  • In-Principle Approval Fee: Equal to 10% of the full license fee, due when in-principle approval is granted.
  • License Fee: The remaining 90% of the license fee is payable before final license issuance. This fee is calculated based on the license category and scope of operations (examples might run into the high six or seven figures for major resorts, though official rates are pending release).
  • Renewal/Maintenance Fee: A yearly fee (often a “maintenance” or “renewal” fee) is due each year to keep the license active. This is generally comparable to the initial license fee and is non-refundable.
  • Timeline: The GCGRA has not set formal deadlines, but publicly states it will process applications smoothly and promptly. Applicants should anticipate multiple months for the full cycle (initial intake, reviews, approvals, and company set-up). Prompt submission of complete documentation and fees can help avoid delays.

5. Ongoing Compliance Requirements

Licensed gaming entities face continuous obligations to maintain their license as enumerated below:

  • AML/CFT Compliance: Operators must strictly comply with UAE Anti-Money Laundering and Counter-Terrorism Financing laws. Robust customer due diligence, reporting of suspicious transactions, and related controls are mandatory.
  • Responsible Gaming: Licensees must implement a comprehensive Responsible Gaming Program (“RG Program”). This includes player education on risks, age-verification, advertising only to adult audiences with no misleading promotions, and providing customer support or self-exclusion tools. Biennial audits of the RG program by a GCGRA-approved auditor are required.
  • Reporting and Updates: Companies must keep the GCGRA informed of any material changes (e.g., changes in ownership/control, financial status, jurisdiction, or any legal investigations). Failure to disclose such changes or to report major compliance issues can lead to penalties or license suspension.
  • Audit and Inspection: The GCGRA will conduct ongoing compliance audits and inspections as part of its oversight. Operators must make records and systems available for review upon request.
  • Annual Renewal: Licenses must be renewed each year. Renewal applications (and payment of the annual fee) are due before the expiry of the current licenses. The GCGRA will verify continued compliance as a condition of renewal.

How HLS-Global UAE Can Help

Navigating the new UAE gaming licensing regime requires careful planning and expert advice. Our firm has experience in UAE regulatory processes and global gaming standards. We assist clients by: identifying the correct license categories; preparing and reviewing all application materials (intake forms, business plans, financial models, RG policies, etc.); managing the GCGRA portal submissions; and coordinating required audits and government interactions. We also ensure ongoing compliance post-licensing (AML programs, RG implementation, reporting). In this still-nascent sector, professional guidance is strongly advised. By leveraging our multidisciplinary expertise, we help you streamline the licensing process and confidently operate within the UAE’s gaming framework.

💼 Partnering with HLS-Global UAE means tapping into a boutique team that knows both the local landscape and international gaming norms. We handle the heavy lifting so you can focus on building your gaming business with confidence.

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Disclaimer: All views expressed in this article are solely for informational purposes and should not be construed as legal advice. This information is for reference only and is bound to change in case of any amendments or changes to applicable laws. We do not assume any responsibility or liability for any errors or omissions in the content of this article, and do not make any warranties about the completeness, reliability, and accuracy of the information expressed in this article.

Business Setup Consultancy in Dubai

Starting a Consultancy in Dubai: Legal Requirements, Licensing, and Ownership Models

Dubai has rapidly evolved into a global hub for businesses, attracting consultants from around the world to set up operations. The city offers a thriving economic landscape, strategic geographic positioning, and investor-friendly policies. Professionals planning to launch a consultancy in Dubai must navigate a complex legal framework and setup process that directly impacts licensing, ownership, and long-term operations. This guide outlines the key steps, legal requirements, and the role of business setup consultants in Dubai in ensuring a smooth market entry.

Choosing the Right Legal Structure

The first step in setting up a consultancy business in Dubai involves selecting the right legal structure. The primary options include Mainland (licensed by Dubai Economy), Free Zone, or Offshore entities. Your choice of structure affects everything—from how you sign contracts and open bank accounts to where you can operate and who can own shares. Mainland companies offer flexibility to operate across the UAE, while Free Zones provide 100% foreign ownership and tax benefits. HLS-Global UAE assists clients in evaluating these structures to align with their specific business goals.

Licensing Requirements for Consultancy Business Setup in Dubai

Obtaining the appropriate license is a crucial requirement. For consultancy businesses, a professional license is mandatory. The process typically involves:

  • Trade name reservation
  • Initial approval
  • Lease agreement or Flexi-desk arrangement
  • Submission of required documentation
  • Payment of license fees

Free Zones like DMCC or DIFC offer streamlined processes, while Mainland licenses require engagement with the Department of Economy & Tourism (DET). HLS-Global UAE ensures seamless license procurement by managing documentation and compliance requirements.

Ownership Models: Full Foreign Ownership vs. Local Sponsorship

Recent reforms in the UAE now allow 100% foreign ownership for most professional activities, including consultancy services. However, some sectors may still require a Local Service Agent (LSA). Free Zones always offer 100% ownership without the need for a local partner. HLS-Global UAE helps investors assess the best ownership model and provides trusted LSA services when required.

Taxation, Compliance, and Regulatory Governance

Consultancies must comply with VAT registration, Ultimate Beneficial Ownership (UBO) reporting, and Anti-Money Laundering (AML) regulations. HLS-Global UAE supports clients in understanding and meeting these regulatory requirements by coordinating with trusted local partners where needed. HLS-Global UAE supports clients with regulatory advisory, helping you understand key compliance areas like VAT, UBO reporting, and AML, while coordinating with licensed partners where specialized tax filings are required.

Why Choose HLS-Global UAE?

HLS-Global UAE stands out as a reliable partner for consultancy business setup in Dubai. With deep experience supporting Japanese businesses and multinationals, the firm offers end-to-end services including entity formation, regulatory advisory, compliance outsourcing, and transaction support. With a client-first approach, HLS-Global UAE ensures your consultancy setup is strategically structured, regulator-ready, and built to scale.

Informative Table:

Aspect

Mainland Setup (DED)

Free Zone Setup

Ownership

Up to 100% Foreign Ownership

100% Foreign Ownership

Market Access

Full UAE Market Access

Limited to Free Zone & Exports

Licensing Authority

Dubai Economy & Tourism (DET)

Free Zone Authority

Office Requirement

Physical Office Required

Flexi-desk or Virtual Office

Conclusion

Setting up a consultancy in Dubai offers immense opportunities but requires careful navigation through legal, licensing, and compliance landscapes. With expert guidance from business setup consultants in Dubai like HLS-Global UAE, entrepreneurs can achieve a successful market entry and long-term business growth. Reach out to HLS-Global UAE for bespoke advice tailored to your consultancy ambitions in the UAE.

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Disclaimer: All views expressed in this article are solely for informational purposes and should not be construed as legal advice. This information is for reference only and is bound to change in case of any amendments or changes to applicable laws. We do not assume any responsibility or liability for any errors or omissions in the content of this article, and do not make any warranties about the completeness, reliability and accuracy of the information expressed in this article.

Anti-money Laundering, AML services

EU Delists UAE from ‘High-Risk Third Countries’ List

Introduction

On July 09, 2025, the European Union officially removed the United Arab Emirates from its “high-risk third countries” AML/CFT list—mirroring the FATF’s grey-list delisting in February 2024. This marks a watershed moment in the UAE’s financial-compliance journey, reflecting material reforms and unlocking tangible benefits for trade, investment, and international partnerships. Businesses can now leverage improved market conditions while ensuring their AML services align with international standards.

1. EU AML/CFT Regime Overview

Under Directive (EU) 2015/849 (4th and 5th AML Directives), the European Commission maintains a dynamic list of high-risk jurisdictions whose shortcomings trigger regulatory compliance services for EDD by EU financial institutions. Countries are reviewed annually based on FATF evaluations and bilateral assessments. While listing imposes automatic EDD, delisting requires demonstrable alignment with global standards—spanning legal frameworks, supervisory capacity, and enforcement outcomes. Organizations operating in both EU and UAE jurisdictions require sophisticated AML services to navigate these evolving regulatory landscapes effectively.

2. From Listing to Delisting: UAE’s Reform Trajectory

Initial Listing (2022): Concerns over limited transparency, beneficial-ownership opacity, and uneven enforcement across sectors, including real estate and precious-metals trading.

Catalytic Reforms:
  • National AML/CFT Strategy 2024–2027: Eleven core objectives targeting risk-based supervision and sectoral outreach (banks, real estate, corporate services).
  • Specialized AML/CFT Courts: Expedited prosecution and increased convictions for predicate offences.
  • Beneficial-Ownership Registry: Mandatory disclosures with inter-agency data-sharing protocols. For guidance on implementing and maintaining your registry disclosures, see our Secretarial Compliance Enhanced Penalty Regime
  • AML Oversight Expansion: Inclusion of VASPs, auditors, and trust-service providers under enhanced supervision.
  • Enforcement Intensification: Over AED 350 million in fines levied by the Central Bank since early 2025.

EU Delisting Rationale: The European Parliament’s decision followed a positive Commission recommendation, underscoring the UAE’s effective implementation of AML/CFT reforms and sustained enforcement track record.

3. What Delisting Means for the UAE

  • Reduced Compliance Burdens: EU banks and asset managers no longer apply blanket EDD to UAE counter-parties—streamlining client onboarding and transaction processing. While compliance requirements are streamlined, businesses still benefit from expert AML services to maintain best practices and competitive advantages.
  • Enhanced Market Access: Smoother cross-border payments and capital flows, with IMF estimates suggesting potential FDI uplifts of up to 3% of GDP and overall capital inflows of nearly 7.6% of GDP post-delisting.
  • Free Trade Agreement Momentum: With regulatory obstacles alleviated, the UAE-EU FTA negotiations—launched April 2025—are poised to accelerate, especially in renewable energy, green hydrogen, and critical-materials trade.

Reputational Upside: Global investors and correspondent banks view the UAE as a mature, reliable financial hub, bolstering its status as a gateway linking Europe, the Middle East, and Asia.

4. Continued Vigilance & Next Steps

Delisting is contingent on sustained compliance. The EU will conduct periodic reviews, and UAE authorities have signaled ongoing enhancements—especially in Regulatory Compliance Services and beneficial-ownership verification—to guard against emerging threats and preserve confidence.

How HLS-Global UAE Can Assist

  • Strategic Advisory: Interpret EU delisting criteria and integrate them into your AML/CFT frameworks.
  • Compliance Optimization: Our comprehensive AML services help tailor EDD and KYC policies to leverage reduced scrutiny while maintaining international best practices.
  • FTA Readiness: Align trade-compliance processes for seamless participation in the upcoming UAE-EU Free Trade Agreement.
  • Regulatory Monitoring: Real-time alerts on EU/ECA list updates and bilateral AML/CFT dialogues.
  • Training & Audits: Conduct bespoke workshops and mock inspections to ensure continued adherence to international standards.

Position your business to capitalize on the UAE’s enhanced financial standing—partner with HLS-Global UAE for end-to-end guidance.

 info@hls-global.ae |  +971562318810

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Disclaimer: All views expressed in this article are solely for informational purposes and should not be construed as legal advice. This information is for reference only and is bound to change in case of any amendments or changes to applicable laws. We do not assume any responsibility or liability for any errors or omissions in the content of this article, and do not make any warranties about the completeness, reliability and accuracy of the information expressed in this article.

anti money laundering, AML services, AML/CFT

Anti-Money Laundering Compliance in the UAE : Legal Overview & Practical Guide

The UAE has recently overhauled its anti-money laundering (AML) framework to align with global standards. At the center is Federal Decree-Law No. 20 of 2018 (as amended by Decree-Law No. 26/2021), which requires businesses to prevent money laundering and terrorism financing. These rules apply broadly – from banks and exchanges to many non-financial sectors – to ensure transparency in financial transactions. In fact, the UAE’s intensified AML efforts were recognized by FATF: the country was removed from the FATF “grey list” in February 2024 after implementing key reforms. This means regulators are now particularly vigilant, and companies should be prepared to meet strict AML standards.

 1. Legal Framework & Scope

Federal AML Law: The cornerstone is Federal Decree-Law No. 20/2018 (and its 2021 amendment), which empowers regulators and the UAE Financial Intelligence Unit (FIU) to oversee compliance and reporting. Cabinet resolutions and Central Bank guidelines flesh out the details (e.g. customer due diligence rules, beneficial-ownership disclosures, UN sanctions screening). In practice, this means every covered business must have a risk-based AML policy in place.

Who Must Comply: AML obligations apply to a wide range of entities. On the financial side, this includes banks, insurance companies, money exchanges, fintechs and other licensed financial institutions. Importantly, the law also covers Designated Non-Financial Businesses and Professions (DNFBPs) – for example, real estate developers/agents (involved in buying/selling property), dealers in precious metals or stones (cash transactions ≥ AED 55,000), lawyers/notaries/accountants handling certain client transactions (e.g. real estate deals, asset management, company formation), and trust or company-service providers (incorporation, director or address services, trustees, nominee shareholders). The law broadly covers any company engaged in those activities, even if not formally licensed as such – “substance over form” means your business must follow AML rules if it performs DNFBP services. In short, if your business deals in large sums or high-risk assets, expect AML rules to apply.

 2. Key Compliance Obligations

Businesses under the UAE AML rules must implement and maintain effective controls. Key requirements include:

  • Customer Due Diligence (CDD): Verify every client’s identity (including beneficial owners) before opening an account or transaction, and assess their money-laundering risk. High-risk clients (e.g. Politically Exposed Persons) require extra scrutiny undertaken by way of an Enhanced Due Diligence (EDD).
  • goAML Registration: All “reporting persons” (financial institutions and DNFBPs) must register on the UAE FIU’s goAML platform. goAML is the online system for submitting Suspicious Transaction Reports (and related forms). The Ministry of Economy has warned that failure to register (and thereby file STRs) can lead to severe penalties.
  • Transaction Monitoring & STRs: Continuously monitor accounts for unusual activity. Any suspicious transaction (no matter the amount) must be reported immediately to the UAE FIU via the goAML portal. Reporting entities must register on the FIU’s goAML system to file Suspicious Transaction Reports without delay.
  • Beneficial Owner Disclosure (UBO Register): Every UAE company must maintain a “Real Beneficiary” (UBO) register and requires that a legal person create and keep on file details of its ultimate beneficial owners. Practically, a UAE company has 60 days from incorporation (or from the law’s implementation) to establish its UBO register and the register must be updated promptly whenever ownership changes (typically within 15 days of learning of a change). Keeping the UBO register updated is now a legal obligation in the UAE and forms part of AML/CFT compliance.
  • Record-Keeping: Keep detailed records of all transactions and customer data for at least five years (six years in the case of entities incorporated in DIFC and ADGM). These records must be retrievable for audits or regulator reviews.
  • Sanctions & Controls: Screen customers and transactions against UAE/UN sanctions lists and block any matches. Entities must subscribe to the national Consolidated Sanctions List (via the EOCN system) and if a UN/terrorism/proliferation list match is found, the funds must be frozen within 24 hours and a Fund Freeze Report (FFR) must be filed through goAML; even a partial match requires a temporary hold and a Partial Name Match Report (PNMR) filing.
  • Compliance Officer & Training: Appoint a qualified AML Compliance Officer- MLRO (Money-Laundering Reporting Officer) or team to oversee the program. Provide regular AML training so staff recognize red flags and know how to report concerns.
  • Independent Audit: Periodically audit and review the AML policy’s effectiveness, updating policies and procedures as needed.

Each of the above is an ongoing duty – not a one-time setup. Regulators expect continuous diligence, for instance updating risk assessments when markets or customers change, or when laws are updated. Non-compliance can lead to heavy fines, license suspension and reputational harm.

3. Building a Strong AML Policy

To meet these obligations, businesses typically draft a written AML policy/manual. Key components of an AML Policy must include the following:

  • Risk Assessment & Governance: A high-level statement of AML commitment, approved by management. Outline how you identify and evaluate money-laundering risks across customers, products and regions.
  • CDD/KYC Procedures: Clear rules for client onboarding – what documents to collect (IDs, corporate documents, proof of address), how to verify them, and when to apply Enhanced Due Diligence (e.g. for complex trusts or PEPs).
  • Transaction Monitoring: Methods and thresholds for ongoing monitoring (including transaction monitoring software or manual reviews) and the mechanism for alerts triggering investigation.
  • Reporting Processes: Step-by-step guidance for staff on identifying suspicious activity and escalating it (internally and via goAML). Specify record-keeping obligations for all reports. If a transaction or account raises “reasonable grounds to suspect” ML/TF, the firm must promptly file a Suspicious Transaction Report (STR) with the FIU within 24–72 hours of detecting a concern. Any tipping-off or disclosure that an STR is being filed is strictly prohibited.
  • Sanctions & Prohibited Activities: Procedures to screen against sanction lists and reject or freeze prohibited transactions (covering UN, local and other applicable sanctions).
  • Roles & Training: Define AML roles – e.g. Compliance Officer duties, internal audit responsibilities – and a schedule for regular employee AML training.
  • Document Retention: Rules for how long and where AML records (customer files, transaction logs, STRs) are stored, ensuring they are readily available for audits.
  • Review & Updates: A provision that the policy will be reviewed at least annually (or when laws change) and updated accordingly.

In essence, the policy is your “playbook” for compliance. It should be practical and company-specific (size and industry), not just boilerplate text. While the above elements are standard, each business tailors the details to its operations and risk profile.

4. Penalties & Enforcement Risks

UAE authorities enforce AML rules stringently and the fines could be enormously hefty as below:

  • Monetary Fines: Violation fines range from AED 50,000 to AED 5 million per breach; license suspensions or revocations may follow.
  • Criminal Liability: Money laundering carries up to 10 years’ imprisonment; failure to report can lead to AED 100,000–1 million fines and jail for responsible individuals.
  • Operational & Reputational Damage: Enforcement actions and public sanctions can disrupt banking relationships and erode stakeholder trust.

Staying inspection-ready and demonstrating proactive compliance are your best defenses.

How HLS-Global UAE Helps You Stay Compliant

Navigating AML rules can be complex. This is where HLS-Global UAE comes to the rescue of our clients to assist them in navigating through every step involved in AML compliance:

  • Customized Compliance Program: We help design or update your AML policy and procedures to fit UAE law and your business risks. This includes drafting KYC forms, checklists, and internal control manuals.
  • Regulator Liaison & Filings: We guide you through FIU/goAML registration and can manage STR filings on your behalf. We also assist with any required filings (e.g. beneficial-ownership data or other regulator reports).
  • Training & Monitoring: Our experts conduct on-site or online AML training for your staff, so they know how to spot and report red flags. We can also review your customer database and transaction reports to spot gaps in your monitoring.
  • Ongoing Support & Audits: We provide annual compliance reviews and update your AML policy as laws evolve. When authorities audit your business, we can prepare your documentation and represent your interests to the regulators.

Partnering with us ensures your business is protected from AML risks. A strong compliance program helps you avoid fines and build trust with banks, investors and regulators. Contact us to review your AML compliance and develop a tailored strategy. Your peace of mind is our priority.

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Disclaimer: All views expressed in this article are solely for informational purposes and should not be construed as legal advice. This information is for reference only and is bound to change in case of any amendments or changes to applicable laws. We do not assume any responsibility or liability for any errors or omissions in the content of this article, and do not make any warranties about the completeness, reliability and accuracy of the information expressed in this article.

UAE Golden Visa Golden Visa categories Golden Visa eligibility UAE

UAE Golden Visa Rumor Debunked – Regulatory Clarification & Client Advisory

Introduction

Recently, various reports have been circulating across media and social platforms suggesting the launch of a new Golden Visa scheme offering lifetime UAE residency for a one-time fee of AED 100,000 (approximately INR 23 lakh). According to these claims, the visa could allegedly be obtained via private nomination through designated third-party agencies, without meeting standard investment or talent-based requirements.

However, following public speculation and rising enquiries, the Federal Authority for Identity, Citizenship, Customs & Port Security (ICP) — the official UAE body overseeing visa and residency matters — has formally denied the existence of such a programme.

This newsletter outlines the nature of the misinformation, clarifies the UAE government’s official position, and provides practical guidance for clients in navigating verified Golden Visa pathways.

 1. What Was Claimed?

The alleged scheme, reported by various non-government news sources and widely shared online, made the following representations:

  • The UAE had opened a nomination-based Golden Visa exclusively for Indian and Bangladeshi nationals.
  • Applicants could secure a lifetime residency visa without business ownership, property investment, or a UAE job offer.
  • The visa would be issued upon payment of a flat AED 100,000 fee (approx. INR 23 lakh), through selected agencies such as Rayad Group and One Vasco.
  • The route required only basic documentation and a clean background check — no need for professional or academic distinction.
  • Nominees would enjoy fast-track processing, family sponsorship rights, and exemption from standard long-term residency criteria.

These claims triggered high interest among investors, professionals, and migration consultants — particularly in India and Bangladesh. For accurate information about legitimate UAE residence visa requirements, applicants should consult official sources.

2. Official Government Clarification

In response to the media coverage, the UAE government — through the ICP — issued an official statement on July 08, 2025, confirming the following:

  • There is no officially approved or active “nomination-based” Golden Visa programme based on a flat-fee model.
  • No private agency or consultancy has been authorized to issue, collect payment for, or directly nominate individuals for Golden Visas on behalf of the UAE government.
  • The only valid Golden Visa categories remain those publicly listed on official UAE portals (including u.ae, icp.gov.ae, and emirate-level immigration authorities).
  • Any updates or additions to visa categories or eligibility criteria are announced formally through Cabinet Resolutions or via the websites of the ICP, GDRFA, or the Office of the Cabinet.

The ICP further cautioned applicants against falling prey to fraudulent promises or unauthorized “express visa” services offered by intermediaries. Professional regulatory compliance guidance ensures adherence to official procedures.

3. What Remains Valid: Golden Visa Categories

The official Golden Visa regime, introduced in 2019 and enhanced in 2022, remains active and accessible via the following recognized categories:

  • Investors in Public Funds/Real Estate Investors: AED 2 million+ property ownership.
  • Entrepreneurs: Founders of start-ups or holders of UAE-registered commercial licences having a project value of more than AED 500,000.
  • Skilled Professionals: Earning basic prescribed monthly salary (around AED 30,000 monthly as of now) in fields such as science, education, law, healthcare, etc.
  • Outstanding Specialized Talents: In fields such as science, engineering, education, culture and arts- like doctors, inventors, artists, executives, athletes, etc.
  • Scientists & Researchers: Recognized by the Emirates Council of Scientists.
  • Outstanding Students & Graduates: From top global and UAE institutions.
  • Frontline Workers & Humanitarians: Those with exceptional service to public health or community impact.

All applications must be filed through official government channels, often with the support of a local sponsor, proof of income, or investment credentials.

How HLS-Global UAE Can Help

As a licensed business advisory and management consultancy firm, HLS-Global UAE assists clients with verified and compliant Golden Visa pathways, including:

  • Eligibility Assessment: We assess individual profiles against official categories to determine the most suitable route.
  • Document Preparation: Our team assists in compiling investment proofs, employment letters, professional certifications, and police-clearance documents.
  • Filing Support: We coordinate applications through GDRFA, ICP, or other government-authorised portals—ensuring accuracy and compliance at every stage.
  • Renewals & Advisory: For existing visa holders, we provide end-to-end support for renewals, family sponsorships, and related legal obligations.
  • Regulatory Monitoring: We stay up to date with Cabinet-level decisions and immigration policy changes to protect our clients from misinformation.
For specialized support, Japanese clients can also access our Japan Desk services.

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Disclaimer: All views expressed in this article are solely for informational purposes and should not be construed as legal advice. This information is for reference only and is bound to change in case of any amendments or changes to applicable laws. We do not assume any responsibility or liability for any errors or omissions in the content of this article, and we do not make any warranties about the completeness, reliability, and accuracy of the information expressed in this article.

UAE secretarial compliance Corporate governance UAE Cabinet Resolution 102/2022

Secretarial Compliance for Companies in the UAE Enhanced Penalty Regime

Back in November 2022, the UAE dramatically expanded its fines for corporate secretarial lapses under Cabinet Resolution 102/2022, amending Federal Decree-Law 32/2021 (the Commercial Companies Law). What was once mere procedural oversights now carry substantial, per-occurrence fines—up to six figures in dirhams. Both mainland and free-zone companies must now treat minute-taking, register-keeping, and timely filings as mission-critical.

With regulators empowered to suspend licenses, block director appointments, and even dissolve companies for repeat breaches, businesses can no longer afford lapses in basic secretarial duties. This newsletter walks you through the updated obligations, the new fines framework, and how HLS-Global UAE ensures your compliance, penalty-free.

1. Regulatory Framework & Penalty Highlights

Scope & Applicability
  • Mainland Entities under the Commercial Companies Law face the full suite of new fines.
  • Free-zone entities (DIFC, ADGM, DMCC, etc.) enforce similar secretarial rules via local regulations; federal UBO (Ultimate Beneficial Ownership) and certain AML compliance requirements apply across all jurisdictions.
Key Changes in 2022
  • Introduction of fixed fines for secretarial breaches to maintain registers, hold meetings, file resolutions, amend corporate documents, and more.
  • Fines are now per occurrence and escalate on repeat breaches.
  • Regulatory bodies are empowered to suspend licenses, block director appointments, and, in extreme cases, dissolve offending companies. Professional regulatory compliance services help avoid these severe consequences.
Enforcement Authorities
  • Ministry of Economy (MoE): Main overseer for onshore companies.
  • Free-Zone Authorities: DIFC Registrar, ADGM Registration Authority, DMCC Licensing, each with parallel enforcement powers.

2. Core Secretarial Duties & Penalties

Compliance Item

Requirements

Penalty

Corporate      Governance Rules

Ensure compliance with the statutory corporate governance standards

Up to AED 10 million – Public JSC

Change in Trade Name

Ensure compliance with the decision to change the Company’s trade name

AED 500 per month (capped at AED 5,000 yearly)- L.L.C.

AED 1,000 per month (capped at AED 10,000 yearly)- Private JSC

AED 1,000 per month (capped at AED 10,000 yearly)- Public JSC

MoA/Article Amendments

File any change (capital, activity, shareholding) within the statutory deadline

AED 1,000/month (capped AED 10,000/year)- L.L.C.

AED 1,500/month (capped AED 15,000/year)- Private JSC

AED 2,000/month (capped AED 20,000/year)- Public JSC

Convene the General Assembly when losses ≥50% of capital

Within 4 months of financial year-end; keep minutes on file

AED 50,000- L.L.C.

AED 100,000- Private JSC

AED 200,000- Public JSC

Share Certificates

Ensure compliance with the rules on issuing, endorsing, or safeguarding physical share certificates.

AED 200,000- Public JSC

Auditor Appointment

Ensure the appointment of an auditor duly licensed by the MoE/Authority.

AED 50,000- Private JSC

AED 200,000- Public JSC

Inspection Cooperation

Provide access to premises, records, and systems on request

AED 5,000- L.L.C.

AED 10,000- Private JSC

AED 200,000- Public JSC

Financial Year Accounts

Prepare and present the year-end accounts for board/shareholder approval

AED 50,000- Private JSC

AED 100,000- Public JSC

Accounting & Records

Keep   financial  books & records at the registered office

AED 15,000- L.L.C.

AED 20,000- Private JSC

AED 100,000- Public JSC

Access to Books/Minutes

Provide the partners/shareholders access to the minutes of the General Assembly, books, etc.

AED 5,000 – L.L.C.

AED 10,000- Private JSC

AED 100,000- Public JSC

Board Meeting Invitation to Director

Chairman/Director to send invitation to the Director(s)/Manager(s)  for Board Meeting

AED 3,000- L.L.C.

AED 8,000- Private JSC

AED 100,000- Public JSC

Registration Process

Ensure the undertaking registration process is completed within 10 (ten) working days from the issuance of the certificate of incorporation

AED 20,000- Private JSC

AED 100,000- Public JSC

Board Formation

Formation of the Board Quorum as per the statutory requirements

AED 10,000- Private JSC

AED 200,000- Public JSC

Board Vacancy & Nomination

Comply with the prescribed procedures in case of vacancy/nomination to the Board

AED 10,000- Private JSC

AED 200,000- Public JSC

Annual General Assembly

Within 4 months of financial year-end; keep minutes on file

AED 5,000 (up to AED 10,000 if regulator-ordered)- L.L.C.

AED 30,000 (up to AED 50,000 if regulator-ordered)- Private JSC

AED 200,000 (up to AED 200,000 if regulator- ordered)- Private JSC

Unauthorized Share Transfers

Process or record transfers outside legal procedures

AED 20,000- L.L.C.

AED 50,000- Private JSC

AED 200,000- Public JSC

Statutory Registers (Shareholders/Directors)

Maintain and update continuously

AED 100,000- Public JSC

UBO Register

Record & updates the Ultimate Beneficial Owners upon any change

AED 20,000 (2nd offence)

AED 40,000 (3rd offence)

Board Meetings

At least 4 per year; written notice & signed minutes

AED 3,000- L.L.C.

AED 8,000- Private JSC

AED 100,000- Public JSC

Note: Repeat offenses trigger double or triple penalties and may lead to license suspension or director disqualification.

3. Compliance Process & Critical Timelines

To stay ahead of penalties, companies should adopt a disciplined secretarial workflow:

Centralized Registers & UBO Tracking
  • Use a digital register system to record all shareholder, director, and UBO changes instantly.
  • Review and reconcile registers monthly to ensure accuracy.
Meeting Management
  • Schedule board meetings quarterly and the Annual General Assembly within four months of year-end.
  • Issue formal notices 7–14 days in advance; circulate agendas and draft minutes promptly.
Document Filing Cadence
  • File the MoA amendments within 30 days of any capital or shareholding change.
  • Submit license renewal applications and corporate registry updates at least 30 days before expiry. New businesses should understand these requirements during UAE business setup to ensure smooth operations.
  • Notify regulators of director or shareholder changes within 30 days.
Record Retention & Inspection Readiness
  • Maintain accounting records and board/shareholder minutes on-site for five years.
  • Conduct quarterly internal audits of secretarial files to verify compliance.
Ongoing Monitoring
  • Subscribe to regulatory alerts for changes in Cabinet resolutions or the free zone rules.
  • Perform an annual “secretarial health check” to identify gaps and remediate them before year-end.

How HLS Global UAE Streamlines Your Compliance

HLS Global UAE’s corporate secretarial practice offers end-to-end support to keep you penalty-free:

► Compliance Health-Check: A rapid 360° audit of your registers, minutes, filings, and policies to spot gaps.

► Document Preparation: Draft and file board resolutions, notices, MoA amendments, and UBO disclosures on your behalf.

Regulator Liaison: We handle all dealings with MoE, free-zone authorities, and UAE financial intelligence units to ensure timely approvals.

► Ongoing Monitoring & Alerts: Automated calendar reminders for meetings, renewals, and filing deadlines so nothing slips through.

► Training & Governance: Workshops for your directors and company secretaries on best practices and new regulatory trends.

“Our proactive approach transforms secretarial compliance from a reactive chore into a seamless, audit-ready process—eliminating fines and freeing you to focus on growth.”

Partner with HLSGlobal UAE to safeguard your business against the UAE’s enhanced secretarial penalties.

📧 info@hls-global.ae  |   🌐 www.hls-global.ae

Disclaimer: All views expressed in this article are solely for informational purposes and should not be construed as legal advice. This information is for reference only and is bound to change in case of any amendments or changes to applicable laws. We do not assume any responsibility or liability for any errors or omissions in the content of this article and do not make any warranties about the completeness, reliability, or accuracy of the information expressed in this article.

Navigating the UAE’s Virtual Asset Licensing Landscape A Strategic Guide for VASPs

As the United Arab Emirates cements its position as a global crypto hub, Virtual Asset Service Providers (VASPs) eyeing expansion into this dynamic region must understand the regulatory landscape. With multiple regulatory bodies across federal and free zone jurisdictions, getting licensed in the UAE requires a tailored, jurisdiction-specific strategy. At HLS Global UAE, we specialize in simplifying this process end-to-end.

Understanding the UAE’s Regulatory Structure for VASPs

The UAE’s approach to virtual asset regulation is multi-tiered and jurisdiction-specific.

Regulator

Jurisdiction

Role

SCA – Securities and Commodities Authority

Onshore            UAE (Mainland)

Federal oversight of VASPs and digital asset issuance

VARA – Virtual Assets Regulatory Authority

Dubai       (excluding DIFC)

World’s first dedicated VA

regulator

DFSA – Dubai Financial Services Authority

DIFC              (Dubai International Financial Centre)

Independent        regulator under common law

FSRA     –     Financial     Services Regulatory Authority

ADGM   (Abu   Dhabi Global Market)

Robust, mature virtual asset framework

RAKEZ – Ras Al Khaimah Economic Zone

RAKDAO     (Ras    Al

Khaimah        Digital Assets Oasis)

Exclusively   dedicated   to virtual assets

Key Licensing Requirements for VASPs

Across jurisdictions, the licensing requirements typically include:

General Requirements:
  • Corporate structure: UAE legal presence (LLC, branch)
  • Fit & proper management: Background, financial soundness, and experience
  • Capital adequacy: Varies by business model (custody, exchange, broker)
  • Technology & Cybersecurity: Robust infrastructure & AML (Anti-Money Laundering) systems, STR/SAR reporting, KYC policies, ongoing monitoring, and independent audit trails
Specifics by Regulator:
  1. SCA (Mainland UAE)
    • License categories: Brokerage, Custody, Exchange, Platform Operator
    • Capital Requirement: AED 100,000–1 million plus
    • License Process: Pre-application consultation with the SCA, followed by review phas,e and final grant of license
    • Application fee: AED 55,000–500,000 plus (depending on category)
    • Requires local bank guarantee & insurance in some cases
  2. VARA (Dubai)
  • Regulates across 8 activity types (exchange, broker-dealer, custodian) in Dubai World Trade Centre (DWTC) and other non-DIFC Dubai jurisdictions
  • 2-step license process: Initial Approval to Incorporate (ATI) to finalize the firm’s legal incorporation and operational setup, followed by the issuance of a full VASP License
  • Capital Requirement: AED 100,000-1,500,000
  • Application Fees: AED 40,000-100,000 per VA activity; Annual Supervision Fee: AED 80,000-200,000
  • Strict reporting, VA risk framework on AML/CFT, and board governance rules

3. DFSA (DIFC)

  • License under the Investment Token and Crypto Token Regime
  • Risk-based prudential requirements, technology architecture, plus the VA business plan are essential
  • License Process: Authorization Enquiry to be submitted on the DFSA portal, and according to approval thereof, the final application needs to be submitted along with the requisite fee on the portal; Crypto Token recognition request to be submitted separately on the portal
  • Application Fee: USD 15,000-70,000 (depending on the activity); Additional Fee: USD 5,000 (for Crypto Token Recognition)
4.   FSRA (ADGM)
  • Regulatory framework recognizes certain virtual assets, including cryptocurrency
  • VASP Full License: Permits exchange, broker-dealer, custody, and token issuance; Limited Activity License: For targeted services, such as custody-only or ICO
  • Capital: Risk-based (minimum USD 250,000 for VASP custodians)
  • License Process: Engagement with FSRA for feedback on business model, followed by submission along with the requisite corporate documents, and finally the grant of license post-review by FSRA (within 3-4 months typically)
  • Application fee: USD 20,000–40,000; Annual Supervision: USD 15,000–50,000
5. RAKEZ (RAK DAO)
  • Overseen by the RAKEZ, which requires applicants to submit a detailed business plan, a comprehensive AML/CFT framework, and fit-and-proper declarations for senior management
  • Two-step license process – Application with the SCA, which entails pre-approval followed by full licensing – typically completed in 6–8
  • Application Fee: USD 4,500-9,500 plus applicable SCA license fee for VASP

Licensing Process Snapshot (Generic Flow)

  • Business Scoping & Legal Structure Setup
  • Engagement with Regulator (Expression of Interest / Consultation)
  • Submission of VASP License Application
  • Review, Interviews, & Clarifications
  • License Issuance + Go Live Approvals

Timeline: 3 to 9 months, depending on jurisdiction and business complexity.

How HLS Global UAE Helps You Get Licensed – Seamlessly

At HLS-Global UAE, we specialize in end-to-end regulatory licensing and compliance advisory for VASPs. Here’s how we deliver value:

Jurisdiction Mapping: We evaluate your model and identify the most suitable UAE zone and regulator (SCA, VARA, DIFC, ADGM, or RKDAO).

End-to-End Licensing Support: From documentation to regulatory liaison, submission tracking, and handling pre-consultation rounds.

License Documentation: From AML frameworks, business plans, to regulatory compliance – we build compliant and regulator-ready documents.

Post-Licensing Compliance: Ongoing support for transaction monitoring and regulatory updates.

Final Word

The UAE offers a fertile regulatory environment for compliant, growth-focused VASPs. But the complexity lies in picking the right zone and aligning with evolving compliance obligations. With deep legal and regulatory expertise, HLS-Global UAE ensures your crypto venture launches seamlessly – with speed, accuracy, and trust.

Disclaimer: All views expressed in this article are solely for informational purposes and should not be construed as legal advice. This information is for reference only and is bound to change in case of any amendments or changes to applicable laws. We do not assume any responsibility or liability for any errors or omissions in the content of this article, and we do not make any warranties about the completeness, reliability, or accuracy of the information expressed in this article.