UAE Law and Practice Contributed by: Stefan Mrozinski, Gabrielle Margerison (nee Lowe) and Arnold Krutilins, White & Case LLP
through technology and innovation and includes the inauguration of the DIFC’s AI and Web3 incu - bator to establish one of the world’s largest AI and technology companies hubs. Abu Dhabi has further made a concerted effort to accelerate the development and adoption of AI and advanced technologies through part - nerships in the UAE and internationally with a focus on AI infrastructure (including data cen - tres), semiconductors and AI technologies and applications (including AI models). In January 2025, Abu Dhabi launched its Digi - tal Strategy 2025-2027, aiming to establish the world’s first fully AI-powered government by 2027 and allocating USD3.5 billion between 2025 and 2027 to boost digital infrastructure, automate all government processes and inte - grate sovereign cloud computing across all operations. 2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models The UAE’s fintech sector has continued to grow and mature following an increase in the adoption of digital payments, e-commerce activity and an expanding digital banking landscape. A wide range of actors are active in the UAE’s fintech space, from mature businesses to start- ups that operate across a wide range of sectors from open banking and equity crowdfunding through to insurtech, wealthtech and regtech. The predominant verticals that apply in the UAE relate to virtual assets, cryptocurrencies, pay - ments (including with respect to remittances which are of disproportionately large importance in the UAE given its large expatriate population)
and blockchain technology. A continued interest from large virtual asset companies considering whether to relocate to the UAE is expected, giv - en the comparatively developed regulatory land - scape amid increasingly aggressive enforcement actions from Western (and other) regulators in this space. 2.2 Regulatory Regime Overview The UAE is a federation consisting of seven emirates, with Dubai largely seen as the UAE’s international commercial centre and Abu Dhabi being particularly important from a governmental and political perspective. Each emirate is permit - ted to exercise all powers not assigned to the federal level. This includes being authorised to issue its own laws and regulations. From a financial services regulatory perspective, the UAE comprises two categories of jurisdic - tion: • “onshore UAE” : constituting the territories of the seven emirates of the UAE, includ - ing approximately 45 economic free zones that are largely concentrated in the emirate of Dubai; and “offshore UAE” : constituting the financial free zones of the DIFC and the ADGM. Each of the financial free zones are, from a financial services regulatory perspec - tive, separate jurisdictions from “onshore UAE” . Each financial free zone has its own standalone rules and regulations that are largely premised on English common law and are based on benchmarking against the rules of leading international financial centres. “Onshore UAE” Payments In “onshore UAE” , the provision of payment ser - vices is generally regulated by the CBUAE pur - suant to the following.
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