SCA Becomes CMA — Criminal Penalties for Unlicensed Financial Activities
What happened: The Securities and Commodities Authority became the Capital Markets Authority on January 1, 2025, under new federal laws that expand regulatory scope to include virtual assets and cross-border activities.
Why it matters: You now face imprisonment of at least one year and fines up to AED 250 million for conducting unlicensed financial activities.
What to do: Check if your business needs CMA licensing — you have until January 1, 2026 to comply.
Central Bank Law Creates Licensing Trap for Tech Companies
What happened: Federal Decree-Law No. 6 of 2024 consolidated banking, insurance and payments regulation under CBUAE, expanding scope to include technology providers that facilitate financial services.
Why it matters: Even marketing financial products to UAE residents without proper authorization is now a licensed activity requiring CBUAE approval.
What to do: Review if your tech platform or digital service needs CBUAE licensing by September 16, 2025.
Data Transfers Between DIFC, ADGM and QFC Now Streamlined
What happened: Qatar Financial Centre, Dubai International Financial Centre, and Abu Dhabi Global Market mutually recognized each other's data protection frameworks, allowing free data flow between these jurisdictions.
Why it matters: This reduces administrative burdens and compliance costs for businesses operating shared services across these financial free zones.
What to do: Review your data transfer maps and intra-group agreements to remove unnecessary safeguards between these three jurisdictions.
ADGM Court Overrules LCIA Rules in $250 Million Case
What happened: The ADGM Court of Appeal confirmed that mandatory arbitration law at the seat prevails over institutional rules, granting a US$250 million worldwide freezing order despite non-compliance with LCIA procedures. The case arose from financing arrangements where banks issued guarantees for a major development project, with respondents required to channel payments into a designated collection account.
Why it matters: The Court focused on section 31 of the ADGM Arbitration Regulations 2015, which grants ADGM courts power to order interim measures before or during arbitration. This provision is mandatory, applying "notwithstanding any agreement to the contrary". The Court accepted that seeking tribunal consent would have been futile in urgent circumstances.
What to do: Consider ADGM-seated arbitration if you need urgent asset protection in disputes — the courts will act fast even when institutional rules create delays.
FATF Grey List Puts BVI Back on Banking Watchlist
What happened: Kuwait and Papua New Guinea were newly added to the FATF grey list this February, alongside British Virgin Islands and Bolivia added in June 2024.
Why it matters: If you conduct transactions with entities in FATF grey-listed countries, your bank must apply Enhanced Due Diligence, meaning more documentation requests, longer processing times, and potentially higher fees.
What to do: Check if you use BVI structures — your UAE bank may now require extra paperwork and face delays on all BVI transactions.
UK Updates Sanctions Rules for Cayman and BVI Structures
What happened: Important changes to the sanctions regimes applying to the British Overseas Territories, including the Cayman Islands and the BVI, came into force on 11 December 2024, with the UK moving to a single consolidated list for all UK sanctions designations from 28 January.
Why it matters: The definition of "relevant firm" now captures art market participants, crypto asset exchange providers, custodian wallet providers, high value dealers and insolvency practitioners. This means wider compliance obligations for UAE businesses using offshore structures.
What to do: Update your sanctions screening systems from OFSI list to the new UK Sanctions List by 28 January if you hold Cayman or BVI entities.
In medieval England, if you killed someone in a church, you couldn't be executed — but you'd be declared legally dead anyway. Your property went to the Crown, your wife became a widow, and your children were orphaned. The law treated you as a walking ghost who had forfeited all earthly rights. Apparently, being technically alive was considered punishment enough.