Fintech 2025

UAE Law and Practice Contributed by: Stefan Mrozinski, Gabrielle Margerison (nee Lowe) and Arnold Krutilins, White & Case LLP

on the type and nature of the financial activity being conducted. 6.3 Impact of the Emergence of Cryptocurrency Exchanges Both the FSRA and the DFSA have amended their regulatory frameworks over the last few years to bring virtual assets, investment tokens and crypto tokens within the scope of their rules and regulations. Most notable, however, is the establishment of the VARA’s regulatory frame - work and authority in the emirate of Dubai in 2022 and further developed in 2023 and 2024. The VARA is the only regulatory authority in Dubai that is exclusively dedicated to the licensing and supervision of virtual assets and related activi - ties. The activities captured under the VARA’s jurisdiction include the establishment and opera - tion of cryptocurrency exchanges. The authors expect the VARA to issue derivatives-related guidance in 2025. 6.4 Listing Standards Various listing standards exist in order to safe - guard and maintain market confidence and ensure a fair, informed and orderly market. For instance, both the DFSA and the FSRA set out the following listing principles in their Markets Rulebooks. • A listed entity must take reasonable steps to ensure that its senior management and any other relevant employees understand and comply with their responsibilities and obliga - tions. • A listed entity must take reasonable steps to establish and maintain adequate policies, procedures, systems and controls to enable it to comply with its obligations.

• A listed entity must act with integrity towards holders and potential holders of its listed securities. • A listed entity must communicate information to holders and potential holders of its listed securities in such a way as to avoid the crea - tion or continuation of a false market in the listed securities. • A listed entity must deal with the competent regulatory authority in an open and co-opera - tive manner. • A listed entity must ensure that it treats all holders of the same class of its listed securi - ties equally in respect of the rights attaching to these listed securities. The FSRA’s Market Rules set out the following additional listing principles: • the structure and operations of a listed entity must be appropriate for it; and • a listed entity must ensure that the terms that apply to each class of its securities are appro - priate and fair, taking into account voting and other rights. 6.5 Order Handling Rules The SCA Rulebook sets out various order handling requirements, including in respect of receiving, aggregating and executing trade orders and the notification of the execution of a trade order and in its settlement. Both the FSMR and the DIFC Markets Law 2012 set out provi - sions in respect of stop orders which may be issued by the FSRA and the DFSA respectively with regards to listed securities (or crypto tokens in the case of the DIFC). 6.6 Rise of Peer-to-Peer Trading Platforms Peer-to-peer trading is in its nascent stages in the UAE. However, the key challenge posed by

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