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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.

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 enhanced due-diligence (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.

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.
  • 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.
  • 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 virtual-asset oversight 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: Tailor EDD and KYC policies to leverage reduced scrutiny while maintaining 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

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 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.

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 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.

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.

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.

Connect with us on LinkedIn.

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.

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 (Anti-Money Laundering) obligations 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.
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.
  • 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.

uae crypto regilations

Crypto Market Regulation: Global & UAE Overview

Welcome to the first installment of our crypto regulation newsletter series. Over the coming editions, we’ll dive into specifics — licensing, governance, compliance, and more — focusing primarily on the UAE. In this brief kickoff, we’ll sketch out the global regulatory environment and then zoom in on how the United Arab Emirates is approaching digitalasset oversight. Think of this as your crash course on “why regulation matters” and “how things look today,” before we unpack the details in future issues.

🌍Global Snapshot: A Broad-Brush Overview

Global cryptocurrency regulation remains highly fragmented, reflecting diverse national priorities ranging from fostering innovation to ensuring financial stability. While some jurisdictions like the United States, the UK, the European Union, and Japan, have recognized and introduced comprehensive licensing and taxation frameworks on virtual digital assets, including cryptocurrency, others, such as China, have maintained a blanket ban on all cryptocurrency trading and mining operations. In the context of India, the cryptocurrency framework is not yet regulated and is still evolving, with the cryptocurrencies being recognized as “virtual digital assets” and subject to taxation, whose capital gains are taxable at a flat 30% whereas TDS is deducted at 1% of sale consideration. Similarly, across other markets—South Korea, Brazil, South Africa, and the UAE—authorities have introduced licensing regimes obligating the virtual assets service providers (VASPs) to register, impose AML/KYC safeguards, and report large transactions on an ongoing basis, aligning with broader UAE crypto regulations.

Thus, across major economies, regulators have been taking steps towards balancing consumer protection, adherence to anti–money laundering (AML) and combating the financing of terrorism (CFT) protocols, and market integrity against the perceived benefits of digital-asset adoption.

United Arab Emirates: Building a Crypto Hub

The UAE’s approach to cryptocurrency regulation has evolved into a multi-layered framework that balances innovation with robust oversight. At the federal level, the Central Bank of the UAE (CBUAE) introduced the Payment Token Services Regulation in early 2025, explicitly defining “payment tokens” (including stablecoins) and requiring licensure for issuance, conversion, custody, and transfer activities within the UAE. Simultaneously, the Securities and Commodities Authority (SCA) maintains federal oversight of certain virtual asset classifications and collaborates with free-zone regulators to ensure consistency— most prominently Dubai’s Virtual Assets Regulatory Authority (VARA) and Abu Dhabi’s ADGM (Abu Dhabi Global Market).

All virtual asset service providers (VASPs) must be licensed either by the SCA (for onshore/UAE-wide activities) or by VARA (for Dubai, including free zones under DWTC); Dubai‐licensed VASPs are automatically registered with SCA, whereas providers outside Dubai must directly secure SCA approval. In ADGM, the Financial Services Regulatory Authority (FSRA) has governed VASPs since 2018, having broadened its mandate to address NFTs, DeFi, and decentralized autonomous organizations (DAOs) in the line with uae crypto regulations.

In Dubai, the VARA was established under Law No. (4) of 2022—it oversees all virtual asset activities outside the Dubai International Financial Centre (DIFC) and operates tailored rulebooks for custodial staking and issuances, thereby bolstering investor protections and market integrity under evolving uae crypto regulations. Meanwhile, the Dubai Financial Services Authority (DFSA) enforces its regulatory regime within the DIFC, encompassing security token offerings, custody services, and updated AML/CFT requirements. Accordingly, all VASPs intending to operate within the DIFC must obtain a license to conduct financial services in relation to crypto tokens, whereas existing authorized firms must apply for a variation to include these activities.

Within the UAE, all VASPs are subject to stringent AML Laws, requiring comprehensive AML/CFT policies, KYC procedures, transaction monitoring, and sanctions screening. Marketing and promotional materials need pre-approval, must be clear, accurate, non-misleading, and include prominent risk disclosures. Enforcement is backed by the cybercrime law in the UAE, which criminalizes unlicensed crypto trading and related fraud.

Through these concerted efforts, the UAE has emerged as a global leader in virtual asset regulation. ADGM was among the first jurisdictions worldwide to codify a comprehensive VASP framework in 2018, while VARA’s rapid updates in early 2025—particularly its fiat-referenced asset rules and streamlined licensing (including default SCA registration)— position Dubai at the forefront of regulatory best practices. Moreover, the introduction of the RAK Digital Assets Oasis in February 2025, the world’s first free zone dedicated exclusively to virtual asset enterprises, underscores the UAE’s commitment to fostering a supportive ecosystem for cryptocurrencies and demonstrates how its regulatory vision not only aligns with international norms but also actively shapes them.

💡Key Takeaways

🌐Global Regulatory Regime

As of mid-2025, the global regulatory regime for cryptocurrencies oscillates between permissive innovation hubs (e.g., Japan, EU, USA) and stringent prohibitions (e.g., China).

Major economies emphasize AML/KYC, consumer protection, and tax transparency, while grappling with how to balance innovation and systemic risk. With India expected to formalize its approach imminently, and other nations refining licensing or tax frameworks, the regulatory environment will likely converge on core principles—licensing, transparency, consumer safeguards, and AML—while allowing differentiated market-access models aligned with each jurisdiction’s strategic priorities.

UAE’s Multi-Pronged Approach

At the federal level, the SCA has set broad definitions and AML rules. In parallel, free zones like ADGM, DIFC, and now VARA in Dubai have fashioned more detailed, innovation-friendly rules that aim to attract global crypto businesses under the evolving uae crypto regulations. Investors and traders need to know which platforms are properly licensed (federal SCA vs. free-zone regulator) to feel confident that their assets are safeguarded. Startups & Token Issuers must decide where to incorporate—ADGM, DIFC, or under VARA in Dubai—based on capital requirements and local presence. Accordingly, the legal & compliance teams will need to map out licensing checklists, AML/CFT workflows, and ongoing reporting requirements before launching any crypto venture in the region.

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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.

How to Navigate Contract Risks in the UAE: Essential Tips for CEOs and CFOs in 2025

Introduction

In the UAE, contracts don’t fail in court—they fail in execution. A poorly structured agreement can cause business deadlock, risk your trade license, or trigger regulatory audits. In 2025, regulatory scrutiny is sharper than ever. The Ministry of Economy, the FTA, and banks now flag contracts that lack clarity around ownership, control, and compliance—making risk assessment in contract management more critical than ever.

CEOs and CFOs must treat risk assessment in contract management as a business-critical step, not a legal formality. It starts well before signing.

At HLS-Global UAE, we guide clients through contract drafting by first examining operational fit. We examine commercial terms that banks will scrutinize, dispute forums that courts will enforce, and governance structures that regulators expect.

Contracts must work in practice, not just on paper. That’s why we align legal language with licensing, AML, and UBO compliance, so you stay bankable, scalable, and protected while doing business in the UAE.

Hidden Risks CEOs and CFOs Miss When Drafting UAE Contracts

Payment terms that don’t match the company’s VAT treatment can trigger tax audits or block recoverable input VAT. Worse, unclear fund flows or beneficiary details can raise AML flags, delaying banking transactions or even freezing accounts. These are not legal hypotheticals—they’re operational disruptions.

Jurisdiction clauses are another blind spot. Without precise language, disputes end up in the wrong forum, costly and unenforceable. Vague POA or management roles often result in shareholder deadlock. And when partners operate under mismatched licenses—say, one mainland, one free zone—the entire deal may be non-compliant. Smart contract drafting backed by real risk assessment in contract management prevents these issues before they surface. HLS-Global UAE structures contracts that hold up in audits, banks, and boardrooms.

Risk Assessment in Contract Management: Key Pre-Signing Filters

  • Before you sign, stress-test your contract like you would a financial model.
  • CEOs and CFOs must conduct risk assessment in contract management with a local enforcement lens, not just legal theory. Start with enforceability: Is the dispute forum practical? DIFC, ADGM, and onshore UAE courts each have distinct recognition and appeal limits.
  • Contract drafting must define who controls payments and where capital moves. Vague language here triggers red flags under the UAE’s AML regime and can stall account approvals.
  • Check alignment with Ultimate Beneficial Ownership (UBO) disclosure, and VAT obligations—non-compliance will compromise your audit trail and tax position.
  • Finally, plan for failure: If the deal goes south, what’s your path to recover funds or enforce terms inside the UAE?
  • At HLS-Global UAE, we decode these risks before contracts are finalized, so execution doesn’t unravel under regulatory or operational pressure.

UAE-Specific Clauses That Need Rethinking in 2025

  • Contract drafting in the UAE demands sharper precision in 2025.
  • Force majeure clauses must now reflect actual risk, not vague disruptions. Courts are stricter, especially post-COVID.
  • Choosing a dispute forum—DIFC, ADGM, or onshore—should align with enforceability, cost, and deal structure.
  • Most overlooked: AML clauses. Banks increasingly review B2B contracts for onboarding steps, UBO clarity, and control rights.
  • Effective risk assessment in contract management now includes mapping regulatory exposure and drafting accordingly.
  • HLS-Global UAE ensures your contracts match current enforcement trends, not outdated templates.

How HLS-Global UAE Fixes Contracts Before They Break?

At HLS-Global UAE, we don’t just review contracts—we design them around operational and regulatory logic.

Instead of waiting for disputes or compliance failures, we embed risk assessment in contract management from day one.
 Our team works across functions—finance, tax, legal, and compliance—to ensure each contract is structurally sound and practically enforceable.

We map out:

  • Regulatory triggers like AML, UBO, and VAT that affect payment flows and partner obligations
  • Escalation paths that offer commercial dispute resolution before costly litigation
  • Banking and licensing alignment so contracts don’t get blocked by enforcement trends or account scrutiny

When we assist with contract drafting, we treat it as a business continuity tool, not just a legal formality.
 We build contracts that banks can work with, regulators can understand, and businesses can execute.

That’s how we help clients avoid breakdowns—before they happen.

Final Word: Contract Management Is Now a Business Continuity Function

In 2025, contracts are more than legal documents—they’re critical to your business continuity. CEOs and CFOs must treat risk assessment in contract management like reviewing a financial model. This means applying stress tests, maintaining version control, and ensuring full compliance visibility at every stage.

A single ambiguous clause can trigger operational disruptions—frozen accounts, licensing delays, or vendor refusals—costs that hit your bottom line hard. These are not theoretical risks; they translate into real business interruptions.

HLS-Global UAE advises embedding compliance checks for AML, UBO, and VAT right into the contract drafting process. This proactive approach aligns legal language with operational realities and banking expectations.

Make contract drafting a strategic priority. Partner with HLS-Global UAE to build resilient contracts that protect your business, support regulatory compliance, and reduce friction in doing business in UAE. Don’t wait for a crisis to manage your contract risks.

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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 services uae

Business Setup Services UAE: How Much Does It Cost to Start a Business Beyond the Trade License?

Introduction

Most new UAE investors focus on one number—the trade license fee. But that’s just the beginning.

In reality, the license covers only 30–40% of your actual business setup costs. The rest depends on:

  • Your legal structure (LLC, branch, or free zone entity)
  • Type of business activity (especially if it’s regulated)
  • Compliance requirements (AML, UBO, VAT and CT registration)
  • Your chosen jurisdiction—Mainland, DIFC, DMCC, or others, and whether you engage professional business setup services UAE.

If you’re serious about doing business in Dubai, you need a full cost and compliance picture, not just a quick agent quote.

At HLS-Global UAE, we act as advisors first. We don’t just register entities—we design them to support long-term operations, banking access, and regulatory readiness. Our clients get real numbers, clear guidance, and a structure that works from day one. Before you license, get the full view. We’ll help you plan it right.

Direct Costs: License, Approvals, and Visas

If you’re serious about doing business in Dubai, budgeting for direct setup costs isn’t optional; it’s strategic. Start with your trade license. Mainland licenses from Dubai’s DED come with different fees and scope compared to free zones like DMCC or IFZA. Choosing wrong can lock you out of key activities or inflate renewal costs.

Initial approvals vary, too. The Department of Economic Development (DED), the Ministry of Economy, and the Municipality each have distinct clearance timelines and fees, especially for regulated sectors. Then comes your immigration card and visa quotas. These depend on office size and license type. Misjudging this can block employee onboarding or raise future expansion costs. Office space is another non-negotiable. Many licenses require a physical lease, not just a flexi desk, to issue visas or open bank accounts.

Finally, don’t overlook banking setup charges. UAE banks demand high minimum balances and apply monthly fees aggressively. HLS-Global UAE helps you model these upfront, so you stay compliant and cost-efficient from day one.

Hidden Costs Most Firms Don’t Tell You

Many new investors focus only on license fees and office rent. But the true cost of setting up a joint venture goes much deeper, and most firms won’t flag these upfront.

At HLS-Global UAE, we help clients budget for the real-world costs that affect both compliance and operations:

  • UBO and AML documentation: Required for every UAE entity. Missing or incomplete Anti-money Laundering records can delay bank onboarding or trigger account reviews.
  • Legal translation and notarization: All documents submitted to UAE authorities must be in Arabic and notarized locally—an often overlooked cost.
  • PRO and government liaison fees: Licensing, visa processing, and regulatory renewals require ongoing PRO engagement.
  • Insurance obligations: From health insurance to WPS-compliant payroll cover—these are not optional.

We prepare you for all of it—no surprises, no gaps, just clarity.

Compliance and Structuring: Where Poor Planning Gets Expensive

In Dubai, compliance missteps cost more than just time—they can shut down your venture. Choose the wrong license activity, and you risk application rejections or regulatory fines. Use a poor shareholding structure, and you face tax inefficiencies or account restrictions. Neglecting AML or UBO filings can delay your setup—or worse, freeze operations post-launch. The right business setup services UAE can help avoid these pitfalls.

At HLS-Global UAE, we reverse-engineer your proposed venture from commercial goals. Our approach to doing business in Dubai integrates AML compliance, license strategy, and tax planning—so your structure supports growth, not triggers risk.

Cost by Type of Setup (With Sample Ranges)

When doing business in Dubai, startup costs vary widely based on structure, license activity, and visa needs.

Here’s a general range:

  • Sole Establishment: AED 15,000–25,000
  • Free Zone FZCO: AED 20,000–40,000
  • Mainland LLC (2+ visas): AED 35,000–60,000

These estimates cover licensing, registration, and basic visa support. But actual costs depend on factors like regulatory approvals, office space, and required third-party NOCs.

Our advisors provide tailored cost breakdowns after reviewing your business model, ensuring you’re set up-ready from day one, with no surprises.

How HLS-Global UAE Helps Clients Control Setup Costs?

Setting up a JV or new entity in the UAE often leads to cost overruns—not because the market is expensive, but because businesses start without clarity.

At HLS-Global UAE, we take an advisory-first approach. Before you spend, we map your setup path:

  • Entity type based on your exact business activity
  • Visa and quota needs tied to real staffing plans
  • Licensing options based on location, control, and compliance risk

Each setup plan is tailored to your business goals, banking needs, and compliance requirements.

We guide you through:

  • Pre-approval banking coordination
  • UBO disclosures and AML compliance
  • Government fee forecasting

When you’re doing business in Dubai, controlling setup costs starts with avoiding wrong moves. We make your first dirham count—because we design the setup around your operation, not around a brochure.

Final Word: Budget for Setting Up the Right Way

When you’re doing business in Dubai, don’t just opt for the cheapest trade license available. Think like a founder, building for scale, compliance, and banking trust. A low-cost setup may seem attractive upfront, but it often leads to misaligned structures, frozen accounts, and costly reconfigurations down the road—especially if done without proper business setup services UAE.

At HLS-Global UAE, we advise thorough due diligence.
 Consider these factors:

  • Robust licensing framework aligned with UBO and AML compliance
  • A scalable structure that appeals to banks and partners
  • Initial costs that protect your venture against unforeseen regulatory setbacks

Investing in a proper setup is not about immediate savings—it’s about protecting long-term growth and operational resilience.
 Securing the right infrastructure from the start builds confidence among banks, investors, and regulators.
Talk to HLS-Global UAE for real clarity on setup costs and strategic next steps to ensure your venture is built for success in the UAE market.

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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._

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Doing Business in the UAE

UNITED ARAB EMIRATES – A BRIEF BACKGROUND

hls dbiu

UAE GDP :
USD 525 Billion (Approx)

UAE Population :
9.50 Million Approx.
(15% Local; 85% Expats)

UAE FDI :
USD 30.68 Billion (Ranked first
in FDI inflows in MENA Region)

Total Land Area : 71,023.6
square km (in addition 27,624.9
square km of territorial water).

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Official Language: Arabic
Business Language: English
Government correspondence is mainly conducted in Arabic.

The UAE is an Islamic Nation, and the legal system is largely based on Islamic teachings.

WHY UAE?

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HLSDBA
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Strategic Location

UAE is strategically located between Europe, Africa and Asia. It connects potential markets in Asia, Africa, and Europe offering businesses access to a consumer base exceeding almost 2 billion people. Its strategic location offers optimal trading conditions for the UAE and has made UAE a trans-continental trade hub for   the rest of the world.

World Class Infrastructure

The UAE is renowned for its world-class infrastructure. From state-of-the-art airports and seaports to advanced telecommunications and transport networks,  the infrastructure here supports business operations seamlessly.

OPTIONS FOR DOING BUSINESS IN THE UAE
OPTIONS-1
icon Without setting up legal entity in the UAE
  • Directly with UAE customers/clients; or
  • Via a UAE agent or distributor.
OPTIONS-2
icon Execution of Projects in the UAE
  • Fly-in fly-out (to the extent a local license is not required); or
  • Via a sub-contractor; or
  • Unincorporated joint venture (with a local or foreign partner).
OPTIONS-3
icon With legal setup in the UAE
  • There are two main options available to a foreign investor to set up an entity in UAE:
    1. set up in ‘onshore’ UAE (Mainland) to undertake business within that emirate and outside the UAE; and
    2. set up in one of the Free Zones in the UAE to undertake business within the free zone and outside the UAE.
  • Note: It is also possible to set up a business presence as an offshore company in Jebel Ali Free Zone (JAFZA) and Ras Al Khaimah International Corporate Centre (RAK ICC). These offshore companies are not permitted to carry out business in the UAE.
  • The process for establishing a legal entity in the UAE depends on:
    1. jurisdiction in which the company is proposed to be established i.e mainland or free zones;
    2. type of the legal entity; and
    3. nature of its activities.
PROCESS FOR SETTING UP LEGAL ENTITY IN UAE
1

Application

Submitting an application for Initial Approval

2

Reservation

Reservation of a Trade Name

3

Leasing

Arrangement of Lease Agreement (Ejari) for office

4

Documentation

Submission of the required documents, duly attested, mainly:

  • Promoter’s constitutional documents e.g. Certificate of Incorporation, MOA/AOA, Shareholding Pattern;
  • Resolution from Promoter Company for incorporation of the Company;
  • Resolution for the appointment of Manager;
  • Ultimate Beneficial Ownership (UBO) Declaration
5

Registration

Upon the issuance of license, subsequent registration with the Labour Department and Immigration

6

Onboarding

Submission of works contract for the manager and VISA processing

Note: Once Emirates ID is obtained, bank account opening process to be initiated. Banks in the UAE carry out thorough due diligence process due to stringent AML guidelines prevailing in the UAE.
RECOMMENDED ACTION
UAE carries unparalleled business opportunities however due to availability of multiple options and heavy jurisdictional segmentation, it is highly recommended to have a detailed market entry strategy taking into account:
The proposed business model, products and/or services to be supplied;
The nature and location of target customers and suppliers;
Availability of appropriate licensed activities;
Availability of required infrastructure to cater the proposed business model
The office and employee arrangements.

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.

Dubai Market Entry, market entry

Dubai Market Entry: Regulatory Triggers Foreign Investors Can’t Afford to Miss

The UAE remains a magnet for international investors due to its strategic location, robust infrastructure, and business-friendly environment. However, understanding and complying with the regulatory framework is crucial for foreign investors and multinational companies considering entry into the UAE market. The UAE’s evolving legal and tax landscape demands meticulous planning, especially regarding company formation and doing business in Dubai or any of the other Emirates. Navigating Dubai market entry requires a clear understanding of these regional distinctions.

One of the first regulatory decisions investors face is selecting the appropriate jurisdiction: mainland, free zone, or offshore. Mainland businesses, licensed by the Department of Economic Development (DED), can trade anywhere in the UAE and participate in government tenders. Free zones such as DMCC, DIFC, or ADGM offer 100% foreign ownership and sector-specific advantages but limit commercial activity within the UAE mainland unless local agents are used. Offshore structures, regulated by jurisdictions like JAFZA Offshore or RAK ICC, are designed for holding assets or international trade, not local operations.

A major trigger for businesses entering the UAE is the introduction of Corporate Tax in 2023. A 9% tax now applies to profits exceeding AED 375,000, making it essential for foreign companies to plan tax structures carefully. Furthermore, VAT compliance becomes mandatory if annual turnover surpasses AED 375,000, requiring registration with the Federal Tax Authority (FTA), accurate invoicing, and timely filings. These tax compliance obligations form a critical part of any Dubai market entry strategy.

Another sensitive area is Ultimate Beneficial Ownership (UBO) disclosure. All UAE-registered entities must submit UBO details to the Ministry of Economy, ensuring transparency about who controls the business. Alongside this, Anti-Money Laundering (AML) rules now apply to Designated Non-Financial Businesses and Professions (DNFBPs), such as real estate companies and precious metal traders. These entities must adopt internal compliance programs and file suspicious activity reports where necessary.

Foreign investors must also consider industry-specific approvals, especially for sectors like healthcare, education, banking, and logistics. These may involve the Ministry of Health, KHDA, Central Bank of the UAE, or the Telecommunications and Digital Government Regulatory Authority (TDRA), depending on the nature. Without the correct license, operations can be stalled or even penalized post-incorporation. Proper licensing is one of the key steps in a smooth Dubai market entry process.

Labour laws and visa regulations are another area of regulatory importance. Work visas for shareholders, directors, and staff are linked to the type of license and the office space leased. The Ministry of Human Resources and Emiratisation (MoHRE) governs employment contracts and mandates for Emiratisation in some sectors. Delays or errors in labor card processing or quota management can derail your market entry timeline.

Equally important is the banking setup, where companies must provide trade licenses, shareholding structures, lease agreements, and UBO details. Some sectors may face enhanced due diligence checks, particularly if linked to higher-risk jurisdictions or cash-intensive businesses. Minimum capital requirements vary by jurisdiction—some free zones require AED 50,000–AED 300,000 in paid-up capital, while others are more flexible.

This is where HLS-Global UAE plays a pivotal role. With deep experience in regulatory strategy, company formation, and multilingual support, HLS-Global UAE helps clients navigate complex UAE market entry scenarios. From legal structuring and Tax registration to intercompany agreements and compliance filings, HLS – Global provides full-spectrum assistance. Our specialists offer tailored guidance for Japanese and other cross-border investors with precision and discretion.

Summary Table: Key Regulatory Triggers for UAE Market Entry Final Thoughts

Area

Requirement

Authority

VAT

Mandatory registration ≥ AED 375,000

FTA

Corporate Tax

Mandatory registration within 90 days from incorporation

FTA

UBO Disclosure

Mandatory for all legal entities

Ministry of Economy

Labour & Visa

Quotas, PRO services, MoHRE filings

MoHRE

Sectoral Licensing

Depending on business type

DED / Free Zones / Regulators

Conclusion

In the UAE, reputation and compliance are assets as valuable as capital. Regulatory oversights—whether in tax, licensing, or labor—can stall or jeopardize an otherwise promising venture. Investors must approach doing business in the UAE with a robust compliance-first strategy. HLS-Global UAE provides the insights and execution support needed to turn market entry into market leadership—smoothly, swiftly, and strategically. Speak to our experts for step-by-step guidance on Dubai market entry tailored to your business model.

Ready to expand into the UAE? Connect with HLS-Global UAE today for personalized and compliant UAE market entry solutions that align with your global business goals.

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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, or accuracy of the information expressed in this article._