- UAE — CMA Regulated Activities
Crypto Activities Regulated by CMA — UAE
A precise guide to the virtual asset activities regulated by the Capital Market Authority (CMA) in the UAE — how the regulatory perimeter is defined, how activities map into licensable financial services, and why correct classification is critical to capital, compliance, and licensing outcomes.
CMA Activity Framework — At a Glance
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Activity-based perimeter — authorisation is required per activity, not per entity
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Three-layer structure: VA Activities (what) → Financial Activities (how) → Licence Categories (capital and prudential)
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8 core VA activities, 8 financial activities, 6 licensing categories — misalignment across layers is a key licensing risk
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Capital ranges from AED 500K (MTF) to AED 4M (Dealing as Principal) — most VASPs operate across multiple categories
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Custody is separate — exchange licences do not automatically cover client asset custody
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Custody is separate — exchange licences do not automatically cover client asset custody
Overview & Core VASP Regulated Activities — Advisory Through Arranging
Under the FSMR, Any Person Conducting a Virtual Asset Activity in or from ADGM Must Obtain a Licence. Each Activity Has a Defined Perimeter, Capital Requirement, and Governance Expectation.
ADGM regulates crypto on an activity basis — not by label, entity type, or business model description. Each regulated activity carries a defined operational perimeter, prudential and capital requirements, governance and control expectations, AML and Travel Rule obligations, and ongoing supervisory reporting. Misclassification between activities — Agent vs Principal, Broker vs MTF — can significantly impact capital requirements, regulatory burden, and approval timelines.
Strategic Considerations
Influencer marketing is not prohibited — but it is a high-risk channel that requires formal governance structures, compliance obligations built into contracts, and ongoing monitoring. Firms that engage influencers without these controls are creating direct regulatory exposure.
Lower Capital
Lower Capital
Lower Capital
Lower Capital
Lower Capital
Lower Capital
Lower Capital
Lower Capital
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Strategic Considerations
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
Strategic Considerations
Influencer marketing is not prohibited — but it is a high-risk channel that requires formal governance structures, compliance obligations built into contracts, and ongoing monitoring. Firms that engage influencers without these controls are creating direct regulatory exposure.
Advisory / Arranging
Lower Capital
Advisory / Arranging
Lower Capital
Advisory / Arranging
Lower Capital
Advisory / Arranging
Lower Capital
Advisory / Arranging
Lower Capital
Advisory / Arranging
Lower Capital
Advisory / Arranging
Lower Capital
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Overview & Core VASP Regulated Activities — Advisory Through Arranging
VASP Activity — Execution on Behalf of Clients
Dealing in Virtual Assets (Agent Model)
An execution-only model acting on behalf of clients — the firm executes trades but does not trade on its own balance sheet. Order routing, brokerage services, and client onboarding are within scope. The agent/principal boundary is the most critical classification distinction in the ADGM VASP framework.
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
VASP Activity — Execution on Behalf of Clients
Dealing in Virtual Assets (Agent Model)
An execution-only model acting on behalf of clients — the firm executes trades but does not trade on its own balance sheet. Order routing, brokerage services, and client onboarding are within scope. The agent/principal boundary is the most critical classification distinction in the ADGM VASP framework.
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
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If the firm trades on its own account, it becomes Principal Dealing — triggering materially higher prudential requirements and a different regulatory category
VASP Activity — Execution on Behalf of Clients
Dealing in Virtual Assets (Agent Model)
An execution-only model acting on behalf of clients — the firm executes trades but does not trade on its own balance sheet. Order routing, brokerage services, and client onboarding are within scope. The agent/principal boundary is the most critical classification distinction in the ADGM VASP framework.
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
⚡
If the firm trades on its own account, it becomes Principal Dealing — triggering materially higher prudential requirements and a different regulatory category
VASP Activity — Execution on Behalf of Clients
Dealing in Virtual Assets (Agent Model)
An execution-only model acting on behalf of clients — the firm executes trades but does not trade on its own balance sheet. Order routing, brokerage services, and client onboarding are within scope. The agent/principal boundary is the most critical classification distinction in the ADGM VASP framework.
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
⚡
If the firm trades on its own account, it becomes Principal Dealing — triggering materially higher prudential requirements and a different regulatory category
⚖️
Activity-Based
ADGM licences the activity — not the entity type, label, or business model description. Classification determines capital and regulatory burden
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7 VASP Activities
Advisory, Agent Dealing, Principal Dealing, Arranging, Asset Management, Custody, and Exchange (MTF) — each with distinct requirements
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3 FRT Categories
Stablecoin issuance, use in regulated activities, and money services — each requiring specific authorisation and reserve obligations
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Misclassification Risk
Agent vs Principal, Broker vs MTF — wrong classification can trigger unnecessary capital requirements, extended timelines, and enforcement exposure
Overview & Core VASP Regulated Activities — Advisory Through Arranging
Under the FSMR, Any Person Conducting a Virtual Asset Activity in or from ADGM Must Obtain a Licence. Each Activity Has a Defined Perimeter, Capital Requirement, and Governance Expectation.
ADGM regulates crypto on an activity basis — not by label, entity type, or business model description. Each regulated activity carries a defined operational perimeter, prudential and capital requirements, governance and control expectations, AML and Travel Rule obligations, and ongoing supervisory reporting. Misclassification between activities — Agent vs Principal, Broker vs MTF — can significantly impact capital requirements, regulatory burden, and approval timelines.
01
Activity-Based
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
01
Activity-Based
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
01
Activity-Based
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
01
Activity-Based
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
01
Activity-Based
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
01
Activity-Based
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
5-Step Decision Framework
Work Through Each Step to Determine Your MAS Licensing Position
Follow the five steps in sequence. Your answer at each stage either confirms a licensing requirement or narrows the analysis further. This framework is a decision tool — your specific position requires professional analysis of your actual business model.
STEP 02
Stage 2
Where is your business operating — in Singapore, or from Singapore?
This is the jurisdictional gateway question. MAS jurisdiction is triggered both by operating in Singapore and by operating from Singapore — even where all clients are located overseas. The FSM Act specifically captures cross-border digital token services conducted from Singapore.
Stage 2
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
Stage 2
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
Stage 2
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
STEP 03
Stage 2
Where is your business operating — in Singapore, or from Singapore?
This is the jurisdictional gateway question. MAS jurisdiction is triggered both by operating in Singapore and by operating from Singapore — even where all clients are located overseas. The FSM Act specifically captures cross-border digital token services conducted from Singapore.
Stage 2
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
- Executing client trades on their behalf
Stage 2
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
STEP 04
Stage 2
Where is your business operating — in Singapore, or from Singapore?
This is the jurisdictional gateway question. MAS jurisdiction is triggered both by operating in Singapore and by operating from Singapore — even where all clients are located overseas. The FSM Act specifically captures cross-border digital token services conducted from Singapore.
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
STEP 04
Stage 2
Where is your business operating — in Singapore, or from Singapore?
This is the jurisdictional gateway question. MAS jurisdiction is triggered both by operating in Singapore and by operating from Singapore — even where all clients are located overseas. The FSM Act specifically captures cross-border digital token services conducted from Singapore.
Stage 2
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
Stage 2
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
Stage 2
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
Stage 2
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
STEP 04
Stage 2
Where is your business operating — in Singapore, or from Singapore?
This is the jurisdictional gateway question. MAS jurisdiction is triggered both by operating in Singapore and by operating from Singapore — even where all clients are located overseas. The FSM Act specifically captures cross-border digital token services conducted from Singapore.
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
Stage 2
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
You are likely performing a regulated DPT activity under the PSA. The breadth of activities captured means most operational crypto platforms trigger at least one category. Proceed to Step 3.
How We Help
MAS Marketing Compliance — What We Deliver
We translate MAS advertising and conduct expectations into practical, audit-ready frameworks — aligned with how MAS reviewers assess marketing compliance during licensing and ongoing supervision.
Strategic Considerations
Managing Assets (highest base fee)
USD 25,000
Managing Assets (highest base fee)
USD 25,000
Managing Assets (highest base fee)
USD 25,000
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Audience targeting is a compliance obligation — not just a marketing optimisation
What MAS Looks At
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
- Misleading or false statements in any promotional material or communication
Strategic Considerations
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All marketing materials — including social posts, influencer briefs, and campaign copy — go through a defined pre-publication compliance sign-off process before any content goes live.
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All marketing materials — including social posts, influencer briefs, and campaign copy — go through a defined pre-publication compliance sign-off process before any content goes live.
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All marketing materials — including social posts, influencer briefs, and campaign copy — go through a defined pre-publication compliance sign-off process before any content goes live.
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All marketing materials — including social posts, influencer briefs, and campaign copy — go through a defined pre-publication compliance sign-off process before any content goes live.
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All marketing materials — including social posts, influencer briefs, and campaign copy — go through a defined pre-publication compliance sign-off process before any content goes live.
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All marketing materials — including social posts, influencer briefs, and campaign copy — go through a defined pre-publication compliance sign-off process before any content goes live.
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All marketing materials — including social posts, influencer briefs, and campaign copy — go through a defined pre-publication compliance sign-off process before any content goes live.
✔
All marketing materials — including social posts, influencer briefs, and campaign copy — go through a defined pre-publication compliance sign-off process before any content goes live.
✔
All marketing materials — including social posts, influencer briefs, and campaign copy — go through a defined pre-publication compliance sign-off process before any content goes live.
What MAS Looks At
Influencer marketing is not prohibited — but it is a high-risk channel that requires formal governance structures, compliance obligations built into contracts, and ongoing monitoring. Firms that engage influencers without these controls are creating direct regulatory exposure.
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FSRA Scrutiny Focus, Structuring Strategy & What CRYPTOVERSE Legal Delivers
What the FSRA Scrutinises During Licensing and Supervision — Why Structuring Strategy Matters — and How We Deliver End-to-End ADGM Licensing Support
The FSRA's scrutiny during licensing and ongoing supervision is comprehensive and risk-calibrated. Understanding the specific areas of focus — and structuring the business correctly before the application begins — is the foundation of a successful, capital-efficient licensing strategy. Choosing the wrong activity classification creates compounding problems across every stage of the process.
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Activity Classification & Structuring Strategy
We map every business function against the ADGM regulated activity framework — confirming the correct Financial Services Permissions, identifying misclassification risks, and designing a capital-efficient licensing strategy before any application work begins. Correct classification at this stage determines the capital requirements and regulatory burden across every stage that follows.
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Regulatory Business Plan Drafting
We draft the regulatory business plan — covering all licensed activities, revenue streams, operational flow, client base, risk profile, and financial projections — in the format and depth the FSRA expects. The business plan must address every regulated activity in scope and demonstrate that the full model is understood, correctly classified, and adequately resourced.
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Licensing File Preparation & Submission
We prepare and manage the complete FSRA licensing file — FSP application forms, Approved Person applications, controller and shareholder disclosures, governance documentation, and the full supporting pack — ensuring a cohesive, internally consistent submission that minimises avoidable clarification rounds at the FSRA review stage.
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AML & Travel Rule Architecture
We design the AML/CFT architecture — KYC/CDD procedures, transaction monitoring, sanctions screening, blockchain analytics integration, and Travel Rule implementation — tailored to the specific activities being licensed and the ADGM VASP rulebook. The framework is built to be operational before IPA conditions are satisfied, not drafted as a submission placeholder.
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Custody & Wallet Governance Frameworks
For firms applying for custody permissions, we design and document the full wallet governance framework — hot and cold storage architecture, multi-signature key governance, daily reconciliation procedures, cybersecurity controls, and business continuity planning — to the depth the FSRA expects at both application and IPA condition verification stages.
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Exchange, MTF & Stablecoin Structuring
We advise on exchange and MTF licensing strategy — including multi-activity model design, AVA framework development, market surveillance obligations, and MIR regime compliance — and on Fiat-Referenced Token structuring, including reserve management design, redemption rights frameworks, and the disclosure and transparency requirements applicable to stablecoin issuers in ADGM.
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Exchange, MTF & Stablecoin Structuring
We advise on exchange and MTF licensing strategy — including multi-activity model design, AVA framework development, market surveillance obligations, and MIR regime compliance — and on Fiat-Referenced Token structuring, including reserve management design, redemption rights frameworks, and the disclosure and transparency requirements applicable to stablecoin issuers in ADGM.
🏛️
Exchange, MTF & Stablecoin Structuring
We advise on exchange and MTF licensing strategy — including multi-activity model design, AVA framework development, market surveillance obligations, and MIR regime compliance — and on Fiat-Referenced Token structuring, including reserve management design, redemption rights frameworks, and the disclosure and transparency requirements applicable to stablecoin issuers in ADGM.
Activity Classification, Capital-Efficient Structuring, Licensing File Preparation, AML Architecture, Custody Governance, Exchange Structuring, and End-to-End ADGM Licensing Support
- We map every business function against the ADGM regulated activity framework before any application work begins — because wrong classification at the outset determines the capital requirements and regulatory burden across every subsequent stage
- We design capital-efficient structures — using phased licensing where appropriate, correctly separating activities that require distinct authorisation, and ensuring the licensing strategy reflects the actual business model rather than an optimistic description of it
- We prepare the complete licensing file — regulatory business plan, governance framework, AML architecture, capital model, AVA framework, custody governance, and the full FSRA submission pack — and manage all regulatory engagement throughout the process
- We support post-authorisation operations — including supervision management, variation applications for new activities or tokens, and material change notifications — ensuring the firm's regulatory relationship with the FSRA is well-managed from day one of authorised operations
FAQs
Frequently Asked Questions — MAS Licensing Requirement
Limited testing may be possible through MAS’s regulatory sandbox framework — which allows eligible firms to test innovative financial services in a controlled environment with relaxed regulatory requirements. However, operating without a licence at commercial scale carries the full range of PSA enforcement consequences regardless of intent or stage of development. The sandbox does not provide a commercial-scale exemption and is not an alternative to licensing for operational businesses.
MAS applies a substance-over-form test — avoidance strategies based on technical or commercial structuring rarely succeed. MAS evaluates the economic reality and actual functionality of a business, not the legal labels or contractual arrangements. Firms that structure specifically to avoid a licensing obligation — while continuing to perform the regulated function — create compounding regulatory exposure rather than eliminating it. The substance of the activity determines the regulatory outcome.
You may still be regulated under the Financial Services and Markets Act 2022 if your operations are conducted from Singapore. The FSM Act captures cross-border digital token services provided from Singapore regardless of where clients are located. The jurisdictional test is based on where the service is conducted from — not where clients are based. Firms with Singapore-based operations or management serving overseas users cannot rely on the absence of Singapore customers as an exemption from MAS regulation.
Typically 6 – 9+ months for well-prepared applications — subject to MAS review timelines, the complexity of the business model, and the number of query rounds issued. Applications that are incomplete, have weak AML frameworks, or raise governance concerns take materially longer. MAS approval is highly iterative and evidence-driven — the quality and completeness of the initial submission directly determines how efficiently the process proceeds.
Typically 6 – 9+ months for well-prepared applications — subject to MAS review timelines, the complexity of the business model, and the number of query rounds issued. Applications that are incomplete, have weak AML frameworks, or raise governance concerns take materially longer. MAS approval is highly iterative and evidence-driven — the quality and completeness of the initial submission directly determines how efficiently the process proceeds.
Get Clarity on Your MAS Licensing Position
Check Your Licensing Requirement
Whether you are assessing your position for the first time or preparing to apply, a defensible licensing conclusion before you engage MAS is the foundation everything else is built on. Let us map your activities and deliver your licensing position today.