The federal framework for virtual assets outside the financial free zones. It makes the Securities and Commodities Authority the federal licensing authority for virtual asset service providers, recognises local regulators such as Dubai's VARA, requires VASPs to be licensed and to comply with AML/CFT rules, and prohibits unlicensed virtual asset activity in the UAE.
Cabinet Resolution No. 111 of 2022 is the federal framework for virtual assets and virtual asset service providers (VASPs) outside the financial free zones. Issued on 12 December 2022, it entered into force 30 days after publication (Article 18), on 14 January 2023, and remains in force without recorded amendment.
Article 1 defines a virtual asset as a digital representation of value that can be traded or transferred and used for investment, excluding digital representations of fiat currency, securities or funds, and a VASP as a legal person conducting virtual asset activities for others. Article 3 applies the resolution across the UAE including commercial free zones, but excludes virtual assets inside the financial free zones (DIFC and ADGM), digital securities and digital commodities (which follow the Securities and Commodities Authority's own rules) and payment tokens and stored value facilities within the Central Bank's remit.
Article 4 prohibits any person from engaging in virtual asset activities in the UAE without approval and a licence from the SCA or the relevant local licensing authority, requires the business to be domiciled in the UAE, and bars dealing with unlicensed providers. Article 5 lists the licensed activities: operating a platform, exchange between virtual assets, transfers, brokerage and custody or control services. Article 6 makes the SCA the federal supervisor and rule-maker, and Article 9 requires local licensing authorities (the resolution does not name them; in Dubai this is VARA under Dubai Law No. 4 of 2022) to share VASP data and licences with the SCA, which supervises all licensed VASPs. Article 7 sets minimum licensing conditions (sanctions and criminal checks on applicants and partners, technology and cybersecurity standards, capital, insurance and compliance arrangements, clear risk disclosure to investors and reporting of security breaches); Article 8 requires compliance with the UAE AML/CFT laws.
Article 12 lists the sanctions the SCA or a local authority may impose: warnings, suspension, licence revocation, fines up to AED 10,000,000, disgorgement of profits and referral for prosecution; the detailed schedule is Cabinet Resolution No. 99 of 2024. Article 13 provides a grievance to the SCA Chairman, Article 14 gave existing operators three months to comply, and Article 15 lets the Cabinet delegate SCA functions to local authorities.
Status: in force. Read with Federal Decree-Law No. 10 of 2025, which makes unlicensed VASP activity a criminal offence (Article 32), and with Cabinet Resolution No. 134 of 2025, whose Articles 35 and 36 set VASP AML duties.
Any person carrying on virtual asset activities in the UAE outside the financial free zones, licensed VASPs (platforms, exchanges, transfer, brokerage and custody providers), their partners and senior staff, investors who deal with them, the Securities and Commodities Authority and local licensing authorities such as Dubai's VARA. Excluded: DIFC and ADGM, digital securities, and payment tokens under the Central Bank.
| Article 1 | Defines virtual asset (a digital representation of value tradeable or transferable and usable for investment, excluding fiat currency, securities and funds), VASP, virtual asset platform and distributed ledger technology. |
| Article 3 | Scope: the whole UAE including commercial free zones, but not virtual assets inside the financial free zones, digital securities and commodities under SCA rules, or payment tokens and stored value facilities under the Central Bank. |
| Article 4 | No person may engage in virtual asset activities in the UAE without approval and a licence from the SCA or the relevant local licensing authority; the business must be domiciled in the UAE and may not deal with unlicensed providers. |
| Article 5 | Licensable activities: operating a virtual asset platform, exchange between virtual assets, transfer services, brokerage, and custody, management or control of virtual assets for others; the Cabinet may amend the list. |
| Article 6 | The SCA supervises virtual asset activities and VASPs, issues licensing rules and procedures, checks personal data compliance, issues AML guidance and obtains Central Bank approval on financial stability matters. |
| Article 7 | Minimum licensing conditions: sanctions and criminal-record checks on applicants and partners, technology and cybersecurity standards, capital, insurance and compliance requirements, clear risk disclosure to investors and reporting of breaches. |
| Article 8 | Licensed VASPs must comply with the UAE anti-money laundering and terrorist financing laws and their implementing rules. |
| Article 9 | Local licensing authorities must give the SCA all data, licences and transaction information on their VASPs on request; the SCA supervises every licensed VASP including those licensed locally. |
| Article 12 | Sanctions available to the SCA or a local authority: warning, suspension, licence revocation, fines up to AED 10,000,000, disgorgement of profits and referral to the Public Prosecution. |
| Article 14 | Existing operators had three months from entry into force to regularise their position, extendable by the SCA in the public interest. |
| Article 18 | Published in the Official Gazette and in force 30 days after publication. |
Article 12: warning, suspension of activity, revocation of the licence, a fine of up to AED 10,000,000, disgorgement of profits and referral for criminal prosecution. The schedule in Cabinet Resolution No. 99 of 2024 fines unlicensed virtual asset activity AED 500,000 for a first violation rising to AED 4,000,000, with closure of premises. Federal Decree-Law No. 10 of 2025 adds imprisonment and a fine of AED 200,000 to AED 10,000,000 for operating without the required licence.
When a client wants to run an exchange, custody, brokerage or token business, this resolution decides which door they walk through before we incorporate anything. We first classify the activity against Article 5 and the Article 3 exclusions: a payment token business belongs to the Central Bank, a digital security to the SCA's securities rules, a DIFC or ADGM structure to the DFSA or FSRA, and everything else to the SCA or, in Dubai, to VARA. We then sequence the work so that no entity holds itself out, markets or takes customer assets before the Article 4 approval exists, because the fines in Cabinet Resolution No. 99 of 2024 and the criminal offence in the 2025 AML law attach to the activity, not the paperwork. Our role is the corporate layer: free zone or mainland formation, the UAE domicile Article 4 requires, shareholder and beneficial owner documentation, the AML framework Article 8 demands, and coordination with the licensing authority.
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