CMA Decision No. 4/Chairman of 2023 · UAE Federal
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.
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.
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.
English official text in 5 articles. Open the full text or jump to a provision:
| Article 1 | Limits 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 2 | Required 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 bis | Allowed 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 3 | Allows the Authority to regulate other mechanisms for regularising promoters' status to achieve the purposes of the resolution. |
| Article 4 | Repeals any provision or resolution that contradicts this resolution from its entry into force. |
| Article 5 | The resolution takes effect from the day following its issue on 16 January 2023 and is published in the Official Gazette. |
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.
| Amended by | CMA Decision No. 28/Chairman of 2023 |
| Cites | Former 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.
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