- SVF Activities — CBUAE
SVF Activities Regulated by CBUAE
📍
Map your model against SVF licensing triggers
📋
Design float-protected structures
🔄
Build capital-aligned governance frameworks
⚙️
Draft regulatory business plans
🚫
Manage the file through CBUAE authorisation
01 / Overview
What Requires an SVF Licence?
📐
Defined operational perimeter
🛡️
Float safeguarding obligations
💰
Prudential financial resource requirements
🏛️
Governance expectations
⚖️
AML & conduct obligations
📊
Supervisory reporting requirements
⚠️
02 / Core Regulated Activities
The Regulated SVF Activities
01
Issuing Stored Value
Permitted Scope
- Issuing prepaid electronic value
- Issuing reloadable wallet balances
- Issuing prepaid cards
- Creating device-based stored value
- Creating network-based stored value accounts
Not Permitted Without Licence
- Accepting pre-funded value from the public
- Creating transferable prepaid balances
- Offering stored value systems to UAE customers
🎯
Best suited for: e-wallet operators, prepaid programmes, super apps, digital stored value platforms
02
Operating a Non-Device-Based SVF
Permitted Scope
- Maintaining wallet accounts
- Recording stored balances
- Enabling payments using stored value
- Facilitating P2P transfers (where structured as SVF)
Prudential Expectations
- Float segregation
- Daily reconciliation
- Accounting controls
- Operational resilience
🎯
Best suited for: fintech wallet providers and digital prepaid platforms
03
Operating a Device-Based SVF
Permitted Scope
- Local device storage of value
- Offline transaction capability
- Prepaid usage models
Prudential Obligations
- Float protection
- Secure chip governance
- Fraud prevention controls
🎯
Best suited for: transport cards, prepaid access cards, device-based payment systems
04
Managing and Safeguarding the Float
Mandatory Safeguards
- Segregation from company funds
- Reconciliation controls
- Transparent accounting
- Risk management policies
- Protection against misuse
🚨
05
Cross-Border or Overseas SVF Targeting UAE Customers
CBUAE Jurisdiction Triggers
- Markets to UAE residents
- Accepts AED
- Uses Arabic-language targeting
- Maintains UAE banking relationships
- Establishes physical presence in the UAE
- Targets UAE users via "push" marketing techniques
🎯
Best suited for: foreign wallet operators assessing UAE entry risk
03 / Exemptions
Exemption Categories — Limited Scope SVF
🎁
Loyalty reward schemes
⭐
Bonus point programmes
🏪
Closed-loop merchant systems
📱
Limited digital content systems
🧪
Small-scale float (≤ AED 500K and ≤ 100 customers, subject to sandbox testing)
04 / Combination Models
Combination Models — Regulatory Impact
Structure
Scale
Open-loop wallet
Full SVF licence required
Closed merchant network
May qualify for limited scope
Prepaid device + network wallet
Full licensing
Marketplace holding customer balances
Likely SVF
Foreign wallet marketing to UAE
Licensing exposure assessment required
05 / Prudential Expectations
Prudential Expectations Across All SVF Activities
💰
Financial Resource Adequacy
🛡️
Float Safeguarding Architecture
⚖️
AML/CFT Framework
🏛️
Governance & Fit-and-Proper Standards
📋
Risk Management System
🔒
Internal Controls
⚙️
Technology Governance
🔄
Business Continuity Planning
📊
Regulatory Reporting
06 / Regulatory Scrutiny
What CBUAE Will Scrutinise
🔍
Whether value is truly "stored"
🏦
Float segregation mechanisms
💵
Source of capital
📈
Financial sustainability
🏛️
Governance structure
⚖️
AML compliance robustness
⚙️
Technology resilience
📣
Marketing conduct
🌍
Cross-border exposure
🚩
07 / Structuring Strategy
Structuring Strategy Matters
A properly structured SVF model balances regulatory compliance, capital efficiency, and operational scalability.
Wrong Structure Can:
- Trigger unnecessary licensing
- Increase capital requirements
- Attract enforcement scrutiny
- Jeopardise banking relationships
Proper Structure Delivers:
- Regulatory compliance
- Capital efficiency
- Operational scalability
- Faster authorisation timelines
- Stronger banking partnerships
08 / Our Services
What We Deliver
End-to-end SVF regulatory advisory from classification through CBUAE authorisation.
🔬
SVF Activity Classification
Precise mapping of your model to CBUAE activity categories
✅
Exemption Eligibility Assessment
Determine if limited scope or sandbox exemptions apply
🛡️
Float Safeguarding Architecture
Design segregation, reconciliation, and protection frameworks
💰
Capital Planning
Model financial resource adequacy aligned to CBUAE expectations
📋
Regulatory Business Plan Drafting
Produce CBUAE-ready business plans with financial projections
🏛️
Governance Framework Implementation
Build board, committee, and Fit-and-Proper structures
⚖️
AML Framework Design
Implement risk-based CDD, monitoring, and reporting
⚙️
Technology Governance Alignment
Ensure IT, cyber, and BCP meet CBUAE standards
📁
Full CBUAE Licensing File Management
End-to-end application preparation and submission
FAQs
Frequently Asked Questions
If customer funds are pre-funded and stored, licensing likely applies. The determining factor is whether value is electronically stored for future use in payment or purchase transactions.
Not automatically. Scope and redemption rights determine eligibility. If loyalty points can be redeemed for monetary value or transferred, the exemption may not apply.
Targeted marketing to UAE residents may trigger licensing obligations. The CBUAE assesses cross-border exposure holistically, including language targeting, AED acceptance, and push marketing techniques.
No. It is a core regulatory requirement under the SVF regime. Float protection is the central prudential focus, and failure to implement adequate safeguards may result in enforcement action.
Get Started
Structure Your SVF Model Correctly From Day One
Proper activity classification, float architecture, and governance structuring are essential before engaging the CBUAE. We deliver end-to-end advisory from classification through authorisation.