The New CBUAE Law represents a significant overhaul of the financial regulatory framework of the United Arab Emirates (UAE). It consolidates the regulation of banks, payment service providers, and insurers under a single legislative umbrella, introduces new licensing requirements for emerging-technology providers, and imposes enhanced penalty and enforcement provisions.

Another entirely new provision is Article 62, which expands the CBUAE’s regulatory perimeter to capture activities conducted through emerging technologies, including virtual assets and decentralised finance (DeFi) models.

Article 62 extends the scope of the licensing framework by providing that, subject to existing licensed activities, any person who engages in, offers, issues, or facilitates a licensed financial activity – by any means or through any medium – is subject to the licensing, regulatory, and supervisory authority of the CBUAE.

Importantly, this goes beyond simply prohibiting the carrying out of regulated activities without a license; it now expressly captures the facilitation of such activities, either directly or indirectly. This means that entities providing technological infrastructure, platforms, protocols, or digital tools that enable or support the delivery of financial services may themselves fall within the regulatory perimeter, even if they do not directly offer the underlying financial products or services.

By explicitly capturing facilitation, the New CBUAE Law ensures that firms cannot avoid regulatory oversight by characterising themselves solely as technology providers. Going forward, technology companies, payment processors, and DeFi operators will need to evaluate whether their business models could be deemed to facilitate licensed activities and therefore trigger a licensing requirement under the new framework.