Tim Elliott:
MIRA Business FM, Legal Affairs, this hour on The Morning Drive. I’m Tim Elliott. Don’t forget, you can get in touch with us — [email protected] is the email address. That’s the general email if you’d like to send through a question or comment on anything. You can also find us across social media; just search MIRA Business FM. It’s really that simple.
We’re discussing a couple of new cases today, a few new laws, and this one, I think, is exciting for a lot of people. It’s now part of our daily vernacular: the language of crypto.
Joining me is Ludmila Yamalova, US-qualified lawyer, also known as the “TikTok Lawyer.” Thank you for sticking around, Ludmila.
This is the UAE’s new crypto legislative framework, isn’t it? A new set of regulations. Before we go any further, Ludmila, let me make a statement, and you can give me either a thumbs up or a thumbs down; very gladiatorial in aspect.
The UAE’s crypto-legislative framework really works. It’s a friendly jurisdiction, I would say. Is that fair? Thumbs up or thumbs down?
Ludmila Yamalova:
It is a friendly jurisdiction. Thumbs up, yes.
Tim Elliott:
Oh good! Let’s start positive. I’m looking at the whites of your eyes at the moment, wondering if Caesar’s going to move that thumb. What makes you agree with that?
Ludmila Yamalova:
From a legal standpoint, there are a number of laws specifically dedicated to virtual assets and cryptocurrencies. That alone makes it a friendly jurisdiction. We’re not only acknowledging crypto; we’re creating laws designed to provide a regulated platform while encouraging businesses and companies to set up and conduct virtual asset activities here.
There’s a multi-tiered legal framework — we can talk about that in a minute — covering virtual assets and cryptocurrency in different Emirates. We’ve got federal laws, and then Emirate-specific laws that layer on top of each other like an onion.
These laws continue to evolve — new ones are introduced or amended frequently. So from a legal and public policy standpoint, the government has made it clear that it welcomes virtual asset businesses to look at the UAE as a friendly jurisdiction.
But friendly does not mean easy.
Tim Elliott:
When you asked if it’s friendly, I had to pause, because it depends on what you mean. Is it friendly because it’s easy, or friendly because there’s a clear framework that regulates and welcomes the industry?
Ludmila Yamalova:
That’s really the point I was making. At the federal level, the UAE has even signed an MOU with a crypto platform, allowing certain government fees to be paid in digital currency.
Tim Elliott:
Crypto has always been slightly outside of the norm, not part of the traditional financial system. It’s hard to understand for many, and harder to regulate. So budding founders shouldn’t expect it to be too easy to set up, right?
Ludmila Yamalova:
Exactly. When we talk about virtual assets and cryptocurrency, what makes it exciting is that it hasn’t traditionally been regulated. That “unregulated” nature gives it that edge.
But that’s also the mindset we see with many clients. They come to the UAE, drawn by the government’s welcoming stance, expecting “friendly” to mean “easy.” They assume they can simply set up and start operating without strict oversight.
However, while the UAE is friendly and progressive, it’s not a free-for-all. There are proper regulations.
Tim Elliott:
Yes, maybe “friendly” was too warm and fuzzy a word. But let’s say I decide to set up a crypto business in Dubai. What would I actually need to do?
Ludmila Yamalova:
Good question. There’s not one single crypto law; rather, a series of laws and frameworks. These include regulations from the Central Bank, federal laws, and Emirate-specific laws (for example, those in Dubai, Abu Dhabi, and Ras Al Khaimah).
Some of the first specific crypto laws were introduced around 2020–2022. But even older regulations, like anti-money-laundering and compliance laws, still apply. So, it’s a layered system, not a single “crypto law.”
At a high level, setting up a crypto business involves a three-tiered process:
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Obtain a commercial license: the legal right to operate as a business.
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Choose your Emirate: each has its own system (you can’t have a “federal” company).
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Apply for relevant virtual asset approvals: which vary by Emirate.
So, say you choose Dubai. You must decide whether you’ll operate on the mainland or in a free zone. Not all free zones issue crypto licenses. Only specific ones, such as DIFC, DMCC, or DWTC, are authorized.
If you’re in Dubai, you’ll also be subject to VARA, the Virtual Assets Regulatory Authority. This body oversees the crypto industry and enforces its own detailed “Rulebook.”
Other Emirates have their own regulators; for instance, RAK DAO in Ras Al Khaimah and ADGM in Abu Dhabi.
Tim Elliott:
So even within Dubai, it’s layered: mainland, free zones, and DIFC, each with different systems.
Ludmila Yamalova:
Exactly. Once you choose your zone, you must apply for a VARA license that fits your business activity. There are different categories: advisory, broker-dealer, custody, exchange, lending and borrowing, management and investment, transfer and settlement, etc.
Each comes with specific requirements — including documentation, business plans, and capital thresholds.
Let me give you an example. I had a client who wanted to set up a “simple” crypto platform. They said, “We’re not an exchange or a dealer; we’re just a middleman connecting buyers and sellers.”
But under VARA’s definitions, that counts as broker-dealer services, and if they hold client funds, that’s custodial services. So even seemingly simple models fall under regulation.
Tim Elliott:
Right, and that reflects crypto’s roots outside traditional financial systems.
Ludmila Yamalova:
Yes. The whole industry grew on the premise of being unregulated. But now, because it deals with financial instruments — with money — it must be regulated.
Tim Elliott:
And most economies are still scrambling to catch up, because technology moves faster than legislation.
Ludmila Yamalova:
Absolutely. That’s what makes the UAE stand out — it’s ahead of many jurisdictions. While other countries are still developing their frameworks, the UAE already has several laws in place, putting it at the forefront of crypto regulation.
That’s what makes it friendly; not easy, but progressive and structured.
Tim Elliott:
So where do things stand now, from a legislative point of view?
Ludmila Yamalova:
There are two more key points.
First, competence. When applying to VARA, you must demonstrate knowledge and credibility. Applicants must submit:
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A business plan (activities, revenue streams, risk management, governance, projections)
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Ownership and UBO details
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CVs of senior management showing crypto or financial services experience
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Proof of capital
So it’s not for amateurs — or, as I tell clients, “crypto enthusiasts.”
Second, cost. Licenses are expensive. For example:
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Advisory services: AED 40,000 application fee, AED 80,000 annual fee, AED 100,000 minimum capital.
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Broker-dealer services: AED 100,000 application fee, AED 200,000 annual fee, AED 400,000–600,000 minimum capital.
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Custody and lending licenses: up to AED 600,000+ in capital requirements.
So yes — it’s open to business, but it’s a serious commitment.
Tim Elliott:
There’s the barrier to entry right there. So, in summary: yes, you can set up a crypto business in the UAE, but you must be serious and well-prepared.
Ludmila Yamalova:
Exactly. The UAE welcomes legitimate crypto enterprises, but only serious ones. It’s a regulated financial services industry, not a casual side project.
Compared to other jurisdictions, the UAE’s legal framework is evolved, forward-looking, and pro-business. But it expects professionalism and compliance.
Tim Elliott:
There’s a lot more to discuss, but we’re out of time. Ludmila, always great talking to you.
Ludmila Yamalova:
Thank you, Tim. Always a pleasure to be here.
Tim Elliott:
That was Legal Affairs on MIRA Business FM.
For the full visual experience, watch the episode on YouTube.
