As HE Omar Sultan Al Olama, Minister of State for Artificial Intelligence, Digital Economy and Remote Work Applications participated in the WEF session ‘Finding the right balance for crypto’  announcing that the UAE has not licensed a single crypto exchange, concurrently the Dubai based Virtual Asset Regulatory Authority (VARA)  affirmed this on its website in its latest announcement.

Al Olama told audiences at WEF, that the regulations in UAE are not light. There are extensive regulations at VARA. He affirmed, “ UAE has not issued a single licensed crypto exchange in UAE neither Binance nor FTX.” He explained that there is a four step process  and to date, “no one was able to onboard any customers even last week.”

Concurrently VARA stated on its website, “VARA has not granted any operating permits to date this is a four stage licensing process” VARA’s website explained, that the VARA regime is founded on the principles on enforcing responsible market participation backed by a future-proofed and responsive regulatory framework that remains technology agnostic; that collectively deliver socio-economic stability; robust consumer protection; and jurisdictional resilience.”

As such there are four stages to regulation at VARA, the first is Provisional permit; graduating to a 2-step [(2) Preparatory + (3) Operating] Minimum Viable Product (MVP) license; and culminating at the (4) Full Market Product (FMP) license.

The fourth stage takes into effect after regulations have been tested within the regime. As such according to VARA every Virtual Asset Service Provider [VASP] must go through all 4 stages in this current environment, wherein VARA expects to evaluate, observe, and only then authorize suitably qualified entities to undertake any market servicing activities under its licensing regime.

VARA then clarifies that at this stage the only licenses that have been issued are Stage Gate (1) Provisional or (2) MVP-Preparatory to enable VASPs to fulfill all pre-conditions, and undertake readiness steps establish offices, onboard employees with work visas, secure domestic bank account etc. prior to being in a position to undertake any market operations.

So VARA affirmed that no VARA licensee has, to date, been awarded an MVP-Operating permit.

Each VASP that is awarded an MVP license must comply with the [MVP License Conditions Document] issued by VARA, and strictly adhere to the licensing conditions outlined in the appended letter. One of the MVP conditions is that VA activities during this phase may only be provided to qualified and/or institutional investor segments.

Mass retail consumers are strictly prohibited until the Stage Gate (4) FMP license approval has been secured. [Virtual Assets and Related Activities Regulations 2023] will stipulate relevant licensing conditions and requirements.

VARA adds that when it publishes its full market regulation, it will enable borderless economic opportunity across the global VA industry, protecting investors and market participants, backed by active enforcement of all regulatory requirements beyond security and cross-border compliance including those pertaining to custody and segregation of client money; prudential requirements (viz. insurance and liquidity cover); FATF compliance, market manipulation and/or abuse prevention.

In terms of Virtual Assets Exchanges, VARA has awarded Binance (MVP Preparatory License Issued) while Bybit, Crypto.com, Equiti, GCEX, Huobi, and OKX have provisionary approval and started the process.

In terms of Virtual Assets Payment Services, Zamp has applied and have provisional approval. 

In terms of Virtual Assets Broker – Dealer services those who have applied and been granted provisional approval include BitOasis, CoinMENA, MidChains and Scallop

Virtual Assets Issuance Services include Calvin Cheng Web3.0 Holdings, Hike, Monstera, Prypto, Woonkly Labs, and Xfinite

While under Virtual Asset Custodians only Hex Trust (MVP Preparatory License Issued) and Komainu (MVP Preparatory License Issued)

Virtual Assets Management/ Investment Services: Amber Group, BRE Holdings, Brevan Howard, Fintonia Group, NineBlocks, NOIA Capital, TPS Capital and Q9 Capital have all been granted provisional approvals, first stage. 

Al Olama also noted at the WEF session that the job of a regulator is to try and be proactive and to protect people as much as possible whenever people adopt a technology. He states, “In UAE we have a young population so we need to ensure that we regulate fast because youth are early adopters. He added, “The UAE wants to protect talent since we aim to be the country with the highest per capital talent on earth.”

According to him there are other sides of crypto such as Web3 and UAE wants to attract Web3 and Blockchain talent. Blockchain is a technology of the future given that traceability cannot be removed. This according to H.E. Al Olama is a positive thing for the world as it is easier to trace someone who transacts through Bitcoin than through hard cash.”

He ascertained that regulators across the board need to work together. First bad actors should not be able to move from one place to another, and the same incidents should not be repeated tomorrow.

In terms of DeFi Al Olama believes it is is evolving and is least regulated. He states, “ We want to jump into each vertical on its own, the only issue we have is that while the UAE government can move fast  if we work with other governments as teams and we all scrutinize  every single vertical it is better as we cannot wait for next catastrophe.”

As per a recent PWC Crypto regulation report 2023, the UAE has finalized its crypto regulation, includes AML/ CTF Money laundering and counter terrorist financing rules as well as its travel rule and has already prepared the stablecoin regulation for payments which is awaiting final legislation. ( refer to graph page 8 of report).

For those not familiar with the travel rule, it is a Bank Secrecy Act (BSA) rule [31 CFR 103.33) which requires all financial institutions to pass on certain information to the next financial institution, in certain funds transmittals involving more than one financial institution.

This PwC Global Crypto Regulation 2023 report provides an overview of the crypto regulation landscape, with a focus on financial services. It offers insights into how the regulatory frameworks are developing across the world and seeks to identify how this may impact relevant industry participants and virtual service providers within the financial services sector.

The report notes that UAE authorities are assessing their approach to areas including stablecoins and wider DeFi.

In addition as per the report, the Central Bank of UAE is establishing its position in communicating permissible virtual asset activities to local banks. These include opening accounts for Virtual Asset Service Providers (VASPs) better known as crypto exchanges. 

 UAE Securities Commodities Authority with its Decision on Crypto Assets Activities Regulation (CAAR), regulates the offering, issuing, listing and trading of crypto assets in onshore UAE. This includes the initial coin offering exchanges, marketplaces, crowdfunding platforms, custodian services and related financial services based upon or leveraging crypto assets.

In December 2022 the UAE Cabinet updates some of its legislations including those pertaining to virtual business and virtual assets allowing them to be regulated onshore.

As for the rest of the GCC and Arab countries, the report notes that Bahrain has implemented crypto regulations and AML/CTF  yet has not implemented neither the travel rule nor stablecoin regulations for payments.

Jordan, Kuwait, and Oman have not initiated a crypto regulation process, while KSA and Qatar have prohibited cryptocurrencies.

It is interesting that while the report for example considers that Oman has not initiated the crypto regulation process, Oman had announced in 2021 that it was launching through the Central Bank a high level Oman cryptocurrency task force to study the economic advantages and disadvantages of authorizing the use of cryptocurrencies in the country.

In January 2022 Oman capital markets Authority announced a tender for specialized companies to assist in setting up a legislative and regulatory framework for virtual assets and licensing supervision and regulations of Virtual assets service providers within the Sultanate of Oman. Since then no other announcements have been made.

Both Bahrain and Oman have allowed crypto payments to be made in the country through virtual asset providers. Oman based, cryptocurrency broker, Easy Coins launched its trial of Tether USDT on the Tron Blockchain. Accordingly Easy Coin users in Oman can now purchase TRC20 USDT. At the end of 2021 there were 43 thousand registered crypto wallet addresses in Oman.

In the meantime even stablecoins are being trialled in Oman. The Oman Water and Waste Water Services Company (OWWSC), member of Nama Group, to trial a stablecoin linked to the Oman Riyal. The company signed an MOU with Oman based Digital Digits, the creators of Easy coins and Connected Chains to trial “ Hasalah” a stablecoin Wallet.

While in Bahrain EazyPay, a payments solution provider partnered with Binance’s Binance Pay to launch a regulated and approved crypto payments service offering in the Kingdom.

The Kingdom of Saudi Arabia crypto traders and investors are growing despite the ban on cryptocurrencies and the Central Bank of Saudi Arabia has created a division to study implementation of virtual assets and CBDCs. In 2022, Qatar announced the introduction of its blockchain blueprint for the country.

So while regulations are essential for the growth of crypto ecosystem, and the UAE is leading in this regards, it doesn’t mean that crypto is not being utilized in other countries regardless of their regulatory status. 

On December 20th, the Central Bank of Morocco represented by its governor Abdellatif Jouahri announced in Rabat Morocco that the draft crypto bill to regulate the use of cryptocurrencies is ready.

The announcement was carried out at the press briefing following BAM’s 4th and final quarterly meeting of 2022. Jouahri stressed that the full draft is ready to put in place a proper regulatory framework.

Jouahri stated, “Discussions are to be held with all stakeholders, including the Moroccan Capital Markets Authority (AMMC) and the Insurance and Social Security Supervisory Authority (ACAPS),” 

“We proceeded to a specific definition of the cryptocurrency and prepared a general public survey that details the specifics and use of this virtual currency in Morocco,” he added.

In June 2022, The Central Bank of Morocco, Bank Al Maghrib, announced during its second quarterly meeting that it would be introducing a cryptocurrency bill soon. Abdul Latif Al Jawhari, Governor of Central Bank of Morocco noted that the crypto CBDC committee created in February 2022 is putting in place an appropriate regulatory framework to combine innovation, tech and consumer protection.

He also noted that the crypto bill is being benchmarked against global experiences with IMF and World Bank. He also noted that this regulatory framework will also update the legislation on the fight against money laundering and terrorist financing.

In March 2022, during a session with media He revealed that the Central Bank of Morocco had created a council headed by him to oversee the required regulations for both cryptocurrencies and CBDCs. He stated, “We are in discussions with the Central Banks of friendly nations such as Switzerland, Sweden, and France as well as international financial institutions such as the IMF and World Bank to learn from their expertise and experience.”

Despite the fact that the Moroccan government considers crypto illegal in the country, Morocco has the highest number of crypto owners within the Arab region, followed closely by Egypt. 2.38 percent of Moroccan population own crypto.

Oman based, cryptocurrency broker, Easy Coins announced on twitter that it had launched its trial of Tether USDT on the Tron Blockchain. Accordingly Easy Coin users in Oman can now purchase TRC20 USDT. At the end of 2021 there were 43 thousand registered crypto wallet addresses in Oman. 

LaraontheBlock spoke with Dr. Khalid M.W. Tahhan, Co-Founder, Easy Coins ME on the recent Tether trial. According to Tahhan the reason for choosing to trial tether is that it is the largest stablecoin and there is a huge demand for it in the Omani market. He adds, “Easy Coins is also in the process of launching its own Omani Riyal backed stablecoin which will be backed 1:1 with Omani Riyals, ensuring a better peg than USDT.”

While most consider the crypto market to be falling and bearish, Tahhan feels otherwise. He states, “We at Easy Coins believe that Bitcoin will remain competing as a reserve asset. We also believe a lot of the tokens produced from thin air will lose their value. Finally and most importantly, we believe these public Decentralized blockchains will be the new payment rails of the future and are developing solutions to utilize them.”

He explains that Easy Coins is the first non-custodial crypto broker in the MENA region. He states, “We always believed in self-custody and hence deployed a compliance focused self-custody solution from the start to ensure nothing like FTX can happen to our customers.”

In terms of crypto regulations in Oman, while still not regulated, Easy Coins is a formally registered startup at the Oman Ministry of Commerce and Industry as well as part of Jadara Program of the Oman Ministry of Transport, communication and Information Technology.

In short he states, “We are self-regulated and follow compliance methodologies from Europe in the interim. We will become a licensed entity once the regulators in Oman are ready to license such activities.”

Easy Coins is the only cryptocurrency broker in the region that accepts all Omani Debit and Credit Cards and offers lower payment processor fees when using our service with Omani Debit Card.

Prior to this announcement Easy Coins was trialing a stablecoin backed by the Oman Riyal with the Oman Water and Waste Water Services Company ( OWWSC), member of Nama Group. Oman Water signed an MOU with Oman based Digital Digits, the creators of Easy coins and Connected Chains to trial “ Hasalah” a stablecoin Wallet.

The companies would trial a cryptographic stablecoin pegged to the Omani Riyal to be utilized as payment from subscribers in select OWWSC customer halls as well as on Easy Coin. Payments will be made using Hasalah Digital Wallet.

In June 2022, The Executive President of the Central Bank of Oman, Mr. Tahir Salim Al Amri, commented during the 7t Edition of the new Age Banking Summit on the topic of CBDCs (Central Bank Digital Currencies)  that the Central Bank of Oman is working to issue its own CBDC. 

In Parallel, the Oman Capital Market Authority issued its new Securities Law (46/2022) which stipulates that the authority can “Agree to application of technologies, virtual digital investments or any products or services in the areas related to the provisions of this law, as set out in the Regulation.”

Additionally Oman is working towards tokenization of real-estate. The Oman Capital Market Authority (OCMA) is set to include real estate tokenization in its virtual asset regulatory framework, a report quoting an advisor of the authority has said. According to the report, Oman expects to complete drafting the virtual assets regulatory framework by Q3 of 2022.

On October 27th 2022, Q9 Capital published a press release where they unilaterally announced that they had received a provisional virtual asset approval from Dubai’s Virtual Asset Regulatory Authority (VARA). LaraontheBlock since then has continuously been checking VARA’s website and no Q9 to be seen anywhere. Q9 is a crypto investment management platform offering capabilities to crypto and TradFi firms. So it should be on VARA’s website under TradFi, DeFi Asset Managers section, but it isn’t.

VARA lists all the entities which have applied for a license and have provisional approval. So for example on VARA’s website under Native Crypto Exchanges, users can see Binance [Issued MVP Licence], BitOasis, Bybit, CoinMENA, Crypto.com, FTX Exchange FZE [Suspended MVP License], GCEX, Huobi, MidChains and OKX.

Then under TradFi DeFi Custodians, you have the recently approved Hex Trust [Issued MVP Licence], Komainu [Issued MVP Licence] and then you have those who applied and have a provisionary license but not a full MVP one that include Monstera and Zamp.

In TradFi | DeFi Asset Managers there is Brevan Howard, Fintonia Group, NineBlocks and NOIA Capital. While under TradFi | DeFi Financial Services you have Amber Group, Equiti, Scallop, and TPS Capital

With Native Crypto-Content | DLT Platforms listed are Calvin Cheng Web3.0 Holdings and Woonkly Labs while in TradEcon | DeFi Services there is BRE Holdings, Eros Investments, Hike, and Prypto

Two weeks since the announcement and no Q9. This is despite the fact that VARA is quick to update its website when it has approved or provided preliminary approvals or MVP licenses. In addition in many cases it also publishes a press release.

Q9 had stated that this approval came as it expanded into the UAE and applied for a full operating license in accordance with VARA requirements.  As per the release, Q9 products and strategies can be created and executed on Q9’s platform, such as systematic investment portfolios and white-labeled offerings, within VARA’s framework and distributed globally in an automated, transparent, regulated and compliant manner.

The release added, the full operating license, once received, will allow Q9 to extend products and services to qualified investors and financial service providers. Q9 will also establish a regional hub in Dubai to contribute to developing the ever-expanding virtual asset ecosystem both in Dubai and globally.

The press release even goes on to say that the provisional approval is a major milestone that follows a number of registrations for Q9’s local entities in Hong Kong and Dubai. As a regulation-led platform with robust compliance and security controls that have consumer protection and market integrity at its core, the registration further strengthens Q9’s position.

James Quinn, Managing Partner of Q9, noted “Dubai’s Virtual Assets Regulatory Authority is a testament to the country’s forward-looking stance on digital assets and its willingness to support the industry through collaboration. We look forward to participating in the authority’s robust compliance framework and continue building partnerships as we expand our presence in Dubai to roll out additional services and enhanced products for the region.”

But until LaraontheBlock, sees the Q9 name on VARA’s website, Q9 ‘s provisional preliminary approval is still hanging in the wind!

As per a recent news report Standard Chartered backed institutional cryptocurrency exchange and brokerage firm focused on institutions, is expanding into Abu Dhabi in 2023. Abu Dhabi will be Zodia Markets first presence in the MENA region as it targets growth opportunities.

Zodia went live in July 2022 in the United Kingdom. U.K.-based Zodia Markets is a sister company of Zodia Custody, the digital assets safekeeping platform. Both firms share the same majority shareholder in SC Ventures, the venture arm of Standard Chartered.

At the time of its launch in UK the firm, was granted Financial Conduct Authority approval, with spot trading of bitcoin (BTC) and ether (ETH). 

Zodia Markets has drafted an application to operate in Abu Dhabi but plans to submit a new one in early 2023 after extended talks with regulators.

Chief executive Usman Ahmad told Financial News London that Abu Dhabi is attractive because it has been “forward-looking with respect to putting the regulatory framework in place”.

The United Arab Emirates has sought to capitalize on the lack of clear crypto regulations in Europe and the USA. Abu Dhabi adopted a virtual asset regulatory framework in 2018 through ADGM (Abu Dhabi Global Market), as did Dubai in 2022 with its VARA regulatory authority. 

In a recent report published by CoinCub, the UAE ranked 4th in the third quarter of 2022 as the most favourable crypto economy globally. Germany ranked 1st place, followed by Switzerland at 2nd place, then Australia in 3rd. USA ranked 7th globally.

The crypto economy rankings compiled by Coincub looked into various factors such as favorable crypto outlook, clear crypto tax rules, more transparent regulatory communications and more to rank countries.

As per the report, Germany although not a tax haven, is considered one of the strongest all-around ‘traditional-tax’ crypto economies that reward long-term crypto holders. German law charges zero tax on crypto holdings of over a year.

Switzerland ranked second with its positive crypto regulatory stance and is home to some of the top crypto organizations in the world.

Australia has shown a great appetite for crypto and the government has been equally supportive of it over the past year, pushing positive crypto legislation along with reasonable tax policy.

As per the report the UAE has enormous tax advantages and rises up on their list from 18 in Q2 2022 to 4 due to rapid turn around on all things crypto.  UAE  has a government driving it towards becoming the leading crypto economy in the Middle East with the prospect of zero taxes to pay on crypto gains for those located within the UAE’s zero tax zone. 

Singapore, on the other hand, has established itself as a crypto powerhouse in Asia, with a significant chunk of the population involved in crypto trading and investment.

The U.S dropped to the seventh spot due to its unfavourable crypto tax policy and lack of clarity on the regulatory end. However, the report highlighted that the U.S is the only country to allow crypto to form part of strategic workplace pensions. With some key crypto regulations legislature under work, the U.S could see a significant improvement in its rankings by next quarter.

In terms of growth the USA added over 100 new crypto-related companies, with the UK adding 21, Singapore 13, and Switzerland 10 in Q3 of 2022. The world also saw the addition of some 540 new crypto coins, 52 crypto exchanges of which 43 are decentralized, and 233 new crypto companies.

US still leads the top of crypto economies overall, followed by Singapore.

Binance crypto exchange saw a 49 percent growth in the number of users from MENA region in 2022. As per the news this reflects the growing appetite for virtual assets.

In addition Binance has grown its employee base in Dubai alone to over 400 employees.  This comes as Binance recently obtained its Minimal Viable Product (MVP) license from Dubai’s Virtual Asset Regulatory Authority (VARA) which allows the company to offer a range of approved virtual asset related services to suitably qualified retail and institutional investors in Dubai.

Richard Teng, Regional Head of MENA at Binance, comments, “It is extremely encouraging to see this level of growth in the MENA region, not just in terms of user adoption but also in terms of headcount and new employees in our own teams, particularly in the UAE. We are witnessing rapid adoption of blockchain technology in the region and we believe there is huge potential for the UAE to soon become a leading virtual asset hub.”

He adds, “We’ve got exciting plans for Binance in the MENA region and are putting together a highly skilled team to lead our expansion, setting a firm foundation for our future growth. Aligned with our growth objectives, we remain committed to working closely with local regulators to establish a safe and secure ecosystem, and we will continue our cooperation in Dubai and the wider UAE to develop a robust virtual asset infrastructure that protects the market and the investors.”

Abu Dhabi Global Market (ADGM), the International Financial Centre in Abu Dhabi, announced that its financial regulator, the Financial Services Regulatory Authority (FSRA), has published Guiding Principles on its approach to virtual asset regulation and supervision as a way to outline its expectations for the asset class and service providers in the sector.

The principles state the FSRA’s risk appetite and priorities for the sector, with each principle covering one of the key pillars of ADGM’s holistic approach, which includes a robust and transparent regulatory framework; high standards of authorization; preventing money laundering and other financial crimes; risk-sensitive supervision; enforcement powers for regulatory breaches; and its commitment to international cooperation. They will therefore be of particular relevance to potential applicants to ADGM and other regulators with an interest in this area.

As per the document, The FSRA’s risk appetite for VA activities is such that it will only admit operators to its jurisdiction who at the outset can unequivocally meet the transparent, high standards outlined in its framework. This will maintain the best-in-class reputation of the ADGM ecosystem and instil market confidence to promote growth and investment. 

In addition the document discusses stablecoins, ADGM will only permit those tokens where price stability is maintained by the issuer holding the same fiat currency it purports to be tokenising on a fully backed 1:1 basis. This therefore currently prevents the use within ADGM of other types of stablecoins, such as algorithmic stablecoins.

Emmanuel Givanakis, CEO of the FSRA, said, “These guiding principles will provide greater clarity to investors, other regulators, industry and the wider public of our approach to regulation in this area and key expectations we have set on current virtual asset service providers in ADGM and potential applicants. They also outline the tools we have at our disposal to mitigate the material risks that are born from these activities and the regulatory powers to identify and act upon any misconduct. Consistent with the FSRA’s broader strategy to align with international best practices, these principles make clear the high standards of our framework at a time of increased volatility and regulatory focus.”