Foreign Fund Promotion Status Regularisation

CMA Decision No. 4/Chairman of 2023 · UAE Federal

Official title
Chairman of the Authority’s Board of Directors’ Resolution No. (04/Chairman) of 2023 Concerning Status Regularization Mechanisms to Promote Foreign Fund Units in the State
Arabic title
قرار رئيس مجلس إدارة الهيئة رقم (04/ر.م) لسنة 2023م بشأن آليات توفيق الأوضاع لترويج وحدات الصندوق الأجنبي داخل الدولة
Instrument
CMA Decision No. 4/Chairman of 2023
Issued by
Chairman of the CMA Board
Jurisdiction
UAE Federal
Dates
issued 16 January 2023 · in force 17 January 2023
Status
in force (amended)
Amended by
CMA Decision No. 28/Chairman of 2023
Topics
Investment funds · Capital markets · Licensing
Official source
legislation.uaecma.gov.ae · official text (PDF)
Full text
English official text — 5 articles, 658 words, from the official text
Verified
31 October 2026
Print

Limits promotion of foreign fund units in the State to private offerings to professional investors and counterparties under the Regulations Manual, and sets the steps existing promoters must take to regularise their status.

Summary

Decision No. 4/Chairman of 2023 restricts the marketing of foreign investment fund units in the UAE. Article 1 limits promotion of a foreign fund's units inside the State to private offerings to professional investors and counterparties, under the rules in the Regulations Manual of the Financial Activities (Decision No. 13/Chairman of 2021), and bars any new contract, renewal or amendment for promoting foreign fund units that does not comply. In practice this ended the promotion of foreign funds to retail investors onshore. The decision was issued on 16 January 2023 and took effect the day after issue (Article 5). It is in force as amended by Decision No. 28/Chairman of 2023, which added Article 2 bis.

Article 2 set the transition for existing promoters. They had to tell their clients about the decision immediately while continuing to perform their existing agreements and promoter obligations, and amend their contracts with foreign funds where needed. As an exception, a promoter could keep running existing contracts for up to six months from 1 January 2023, or until the contracts ended if earlier, provided it renewed the registration of the foreign fund units and paid the fee pro rata.

Article 2 bis, added later in 2023, allowed the Authority to let promoters who had registered foreign fund units before 31 December 2022 continue promoting them to retail investors until 31 March 2024 inclusive, on an application with a regularisation plan, renewal of the annual registration and pro rata fees. Both grace periods have now expired, so the position today is the Article 1 rule: foreign fund units may be promoted in the State only by private offering to professional investors and counterparties, through a promoter acting under the Regulations Manual. Article 3 lets the Authority adopt other regularisation mechanisms, and Article 4 repeals conflicting provisions. A fund that wants access to UAE retail investors needs a different route, such as a locally licensed fund under the investment funds regulation.

Who it applies to

Persons promoting units of foreign investment funds in the UAE outside the financial free zones, the foreign funds whose units they market, and UAE professional investors and counterparties to whom units are privately offered.

Contents

English official text in 5 articles. Open the full text or jump to a provision:

  1. Article 1
  2. Article 2
  3. Article 3
  4. Article 4
  5. Article 5

Key provisions

Article 1Limits promotion of foreign fund units in the State to private offerings to professional investors and counterparties under the Regulations Manual, and bars new, renewed or amended non-compliant promotion contracts.
Article 2Required existing promoters to inform clients immediately, amend their contracts with foreign funds, and allowed up to six months from 1 January 2023 to run off existing contracts with renewed registration.
Article 2 bisAllowed promoters with units registered before 31 December 2022 to keep promoting to retail investors until 31 March 2024, on an approved regularisation plan and renewed registration with pro rata fees.
Article 3Allows the Authority to regulate other mechanisms for regularising promoters' status to achieve the purposes of the resolution.
Article 4Repeals any provision or resolution that contradicts this resolution from its entry into force.
Article 5The resolution takes effect from the day following its issue on 16 January 2023 and is published in the Official Gazette.

Obligations and deadlines

  • Promote foreign fund units in the State only by private offering to professional investors or counterparties (Article 1).
  • Do not conclude, renew or amend promotion contracts for foreign fund units that breach the resolution (Article 1).
  • Comply with the promoter's obligations in the Regulations Manual of the Financial Activities (Article 2).

In practice — how Polaris handles it

We meet this rule when a foreign fund manager, or a client acting as introducer, wants to market a fund to UAE residents. The answer is narrow: private placement to professional investors and counterparties only, through a promoter operating under the CMA's Regulations Manual, with no retail marketing. Polaris is not licensed by the CMA and does not promote or distribute fund units. We explain where the line sits, flag the licensing exposure of an unlicensed introducer, coordinate with licensed promoters or with a DIFC or ADGM structure where that suits better, and form and administer the client's own UAE company with its AML and UBO records in order.

History and citations

Amended byCMA Decision No. 28/Chairman of 2023
CitesFormer SCA Law

“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.

Related instruments

Amendment 28/Chairman of 2023 to Foreign Fund Promotion Status Regularisation

CMA Decision 28/Chairman/2023 · UAE Federal · in forceFull text (Arabic)

Amending instrument that changes the Foreign Fund Promotion Status Regularisation (CMA Decision No. 4/Chairman of 2023). The CMA has consolidated its changes into the cur…

Regulations Manual of the Financial Activities (Rulebook)

CMA Decision 13/Chairman/2021 · UAE Federal · in force (amended)Full text

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Circular 1/2024 on unlicensed client solicitation

CMA Circular 1/2024/2024 · UAE Federal · in forceFull text

Warns licensed companies that contracting with individuals or unlicensed companies to solicit clients breaches the licensing rules for introducing activity, and that lice…

Former Promotion and Introduction Regulation

CMA Decision 3/Chairman/2017 · UAE Federal · supersededFull text

Chairman decision organising the promotion and introduction of financial products, now listed by the CMA among superseded regulations.

Capital Markets Law

FDL 33/2025 · UAE Federal · in forceFull text

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Related Polaris services

Source and verification. This record was written from the official text published at legislation.uaecma.gov.ae, read on 31 October 2026. Quoted from that text: “The promotion of the foreign fund's units inside the State is limited to the private offering to the professional investor and/or the counterparty”
Published for general information by Polaris Corporate Services FZ-LLC, a licensed Trust and Corporate Service Provider. It is not legal advice and does not replace the official text, which prevails in case of difference. Arabic is the authoritative language of UAE federal and emirate legislation; English translations are provided by the issuing authorities. Instruments change: check the status and the official source before relying on this page.

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