#Dubái As we move through the final quarter of 2025, Dubai has transitioned from being an "experimental" crypto hub to a sophisticated, institutionally-led financial ecosystem. The latest policy shift is defined by a move toward federal integration, where Dubai’s local regulations now dovetail with broad UAE federal laws to eliminate legal gray areas.
The following sections outline the core pillars of Dubai's latest crypto policy as of late 2025.
The Integration of Federal Decree-Law No. 6 of 2025
The most significant development this year is the full implementation of Federal Decree-Law No. 6. While Dubai’s Virtual Assets Regulatory Authority (VARA) remains the primary boots-on-the-ground regulator, this federal law creates a "regulatory floor" that applies across all emirates.
Under this policy, the Central Bank of the UAE (CBUAE) has asserted direct oversight over any digital asset activity that functions as a "payment tool." This means that while VARA handles the licensing of service providers, the Central Bank now dictates the underlying standards for stablecoins and payment rails. This has effectively ended the era of "regulatory arbitrage" between different free zones.
The End of the "Just Code" Defense for DeFi
A major pillar of the late 2025 policy is the formal inclusion of Decentralized Finance (DeFi) within the regulatory perimeter. Historically, many protocols operated in Dubai under the assumption that being "decentralized" or "open-source" exempted them from financial licensing.
The new policy clarifies that if a protocol or its developers actively target the Dubai market or facilitate significant volume for UAE residents, they are treated as financial service providers. This includes decentralized exchanges (DEXs) and cross-chain bridges. A one-year transitional period is currently in effect, requiring these projects to either decentralize to a point of "zero administrative control" or obtain a formal license by September 2026.
Strict Enforcement of Marketing and "Regulated Communication"
Dubai has significantly increased the penalties for unlicensed crypto promotion. The latest updates to VARA’s Marketing Rulebook now classify social media posts, "refer-a-friend" schemes, and even technical articles that link to unlicensed platforms as "Regulated Communication."
The legal threshold for a violation has been lowered to an objective "knew or should have known" standard. For companies, this means that even if a marketing agency is responsible for a post, the parent crypto entity bears the ultimate criminal and financial liability. Penalties for these violations have reached unprecedented levels, with potential fines scaling up to AED 50 million for repeat corporate offenders.
Recognition of Crypto as Intangible Personal Property
On the judicial side, Dubai has solidified the legal status of digital assets. Following landmark rulings in the Dubai International Financial Centre (DIFC) and local courts, cryptocurrencies are now formally recognized as "intangible personal property."
This policy change is critical for the secondary market and dispute resolution. It allows the Dubai courts to issue Worldwide Freezing Orders (WFOs) against digital assets and provides a clear legal framework for how crypto is handled in inheritance, divorce, and corporate bankruptcy cases. It effectively moves crypto out of the "speculative asset" category and into the same legal class as intellectual property or traditional securities.
Mandatory AML and "Presumption of Knowledge"
Finally, the UAE’s updated Anti-Money Laundering (AML) law, effective as of late 2025, has introduced a strict stance on privacy-enhancing tools. The use of mixers, "privacy coins," or any technology designed to obfuscate the transaction trail is now legally viewed with a presumption of illicit intent.
Licensed providers in Dubai are now required to conduct a "GAP Assessment" to ensure their systems can identify and block any interaction with these tools. Failure to report such interactions can lead to the personal criminal liability of the firm’s compliance officers, reflecting Dubai's commitment to staying off international "gray lists" for good.
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