Dubai and the UAE: three regulators, one digital asset market

Why Dubai

Brogen Macy International is a privately held digital asset holding group based in Dubai. The emirate has done something unusual: it has written rules for digital assets before most markets have decided what to do with them. For a group whose plan involves tokenisation, that clarity matters more than any single incentive. It tells an operator which authority to speak to, which licences exist and what the standards will be.

Dubai: VARA

The Virtual Assets Regulatory Authority was established by Dubai Law No. 4 of 2022, published in March 2022. It regulates virtual assets across the emirate of Dubai, excluding the Dubai International Financial Centre. On 7 February 2023 it issued its Virtual Assets and Related Activities Regulations 2023, with four compulsory rulebooks that apply to every licensed provider and seven activity-specific rulebooks. In general, issuing a virtual asset in Dubai requires prior approval from VARA.

Federal rules sit above this. Cabinet Decision No. 111 of 2022 prohibits anyone from carrying on virtual asset activities in the UAE, outside ADGM and DIFC, without approval and a licence from the Securities and Commodities Authority or a local licensing authority such as VARA.

Abu Dhabi: ADGM

Abu Dhabi Global Market launched one of the world's first comprehensive regimes for virtual assets in 2018, and its Financial Services Regulatory Authority has kept refining it. The framework separates virtual assets from digital securities, which include tokenised securities, and it has since added rules for fiat-referenced tokens. Amendments took effect on 10 June 2025, changing how tokens are accepted for use and raising prudential requirements for firms such as custodians. For tokenised securities in particular, ADGM is an established route.

Dubai International Financial Centre: DIFC

DIFC has its own regime, separate from VARA. Its regulator, the Dubai Financial Services Authority, introduced an investment tokens regime on 25 October 2021 and a crypto token regime from 1 November 2022. Updated rules came into force on 12 January 2026: the regulator no longer publishes a list of recognised crypto tokens, and firms must instead assess and document whether each token they deal with is suitable.

DIFC also took a step that is unusual worldwide. On 8 March 2024 it enacted the Digital Assets Law, DIFC Law No. 2 of 2024, which treats a digital asset as a form of intangible property and sets out how it can be controlled and transferred. Property law of that kind matters directly to anyone planning to tokenise an asset.

How the regimes work together: property

Tokenised property shows the regimes cooperating. The Dubai Land Department's pilot, Prypco Mint, launched in May 2025 and is managed jointly by the Department, which regulates the physical property, and VARA, which regulates the digital side. The tokenisation guide describes it in more detail.

The UAE domain landscape

The .ae country code domain is run by the .ae Domain Administration, which is both the regulatory body and the registry operator and sits within the Telecommunications and Digital Government Regulatory Authority. The group holds names in the UAE as part of its wider domain name portfolio, and a name that is registered in the country where its owner is based is easy to evidence and to represent.

What this means for the group

The group is designing YourBank.app with reference to all three regimes. Which one applies to a given asset depends on its structure and on who will hold it, so the choice will follow legal advice and will be stated on the relevant page. The group does not claim any licence that it does not hold. Its approach to investments and acquisitions treats regulatory fit as a first test.