UAE Trends and Developments Contributed by: Stefan Mrozinski, Gabrielle Margerison (nee Lowe) and Arnold Krutilins, White & Case LLP
to regulate virtual assets. The VARA only has jurisdiction over the emirate of Dubai (exclud - ing the Dubai International Financial Centre (the “DIFC” )). There are also two financial free zones in the UAE, being the Abu Dhabi Global Market (the “ADGM” ) and the DIFC. These financial free zones are considered to be entirely separate jurisdictions from the onshore UAE. The ADGM and the DIFC each has its own highly sophisti - cated standalone rules and regulations that are predicated on English common law. This multi-jurisdictional structure creates a sophisticated but potentially advantageous landscape for fintechs, allowing them to select the regulatory environment that best aligns with their business models and target markets. National Strategies Driving Fintech Growth Beyond the regulatory frameworks established by individual regulators, the UAE has implement - ed several strategic initiatives at both the federal and emirate level to accelerate the adoption of fintech and enhance digital transformation in the financial sector. These co-ordinated strategies provide important context for understanding the regulatory developments within each jurisdiction in the UAE, as they reflect the UAE’s broader vision for financial innovation and modernisation of the financial services sector. Financial Infrastructure Transformation Programme A key federal initiative supporting fintech growth has been the CBUAE’s Financial Infrastruc - ture Transformation Programme (the “FIT Pro- gramme” ). The FIT Programme’s broad aim is to accelerate the digital transformation of the UAE’s financial services sector through nine strategic initiatives:
• card domestic scheme: a unified and secure card payment platform to facilitate growth of e-commerce and digital transactions in the UAE; • eKYC: the development of a unified eKYC programme to facilitate non-face-to-face customer onboarding and ongoing customer due diligence; • Central Bank Digital Currency (CBDC): CBDC for cross-border and domestic payments to address inefficiencies of cross-border and domestic payments; • open finance: regulation to develop a frame - work for open finance services which is man - datory for all financial institutions regulated by the CBUAE; • supervisory technology: advanced supervi - sory technology to support the regulatory and supervisory processes; • innovation hub: a collaborative platform for the engagement, research and development for fintechs; • instant payments platform: a secure, efficient and robust payment platform that will sup - port financial inclusion and enable a cashless society through digital payments; • financial cloud: a secure, resilient and reliable sovereign financial infrastructure; and • excellence and customer experience: sup - porting exceptional customer experiences and fostering a culture of excellence across the financial sector. The FIT Programme was launched in 2023, and several of its initiatives were implemented in 2024, driving the regulatory agenda across the multiple jurisdictions in the UAE. The FIT Programme has established clear priorities for regulatory development while the issuance of the CBUAE’s Open Finance Regulation and other developments demonstrate progress in the execution of the FIT Programme’s vision.
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