The United Arab Emirates (UAE) has introduced one of the most sweeping regulatory overhauls in years, and crypto developers say it amounts to a de facto ban on self-custody.
This new change raises urgent concerns about Dubai’s position as one of the world’s leading crypto hubs.
A new Central Bank law, which came into force on September 16, significantly expands licensing requirements. Specifically, it makes it a criminal offense to offer even basic cryptocurrency tools, such as Bitcoin wallets or blockchain explorers, to UAE residents without permission.
THE Federal Decree-Law No. 6 of 2025published in the UAE Official Gazette, replaces the 2018 Banking Law and introduces a much more aggressive regulatory scope.
While previous rules required licensing for entities offering regulated financial activities, they did not impose criminal penalties for non-compliance.
According to Gibson Dunn’s legal analysis, Section 170 now criminalizes any unlicensed financial activity. Penalties range from imprisonment to fines of between AED50,000 and AED500 million (up to $136 million).
What stands out is that these sanctions apply to companies offering financial products, as well as anyone facilitating them through technology.
This is where the crypto industry experiences the biggest shock.
Developer Mikko Ohtamaa warned that the law “makes it a crime” to offer self-custodial Bitcoin wallets, blockchain explorers or even market data tools like CoinMarketCap without a license from the Central Bank.
“Only Bitcoin you are allowed to own is authorized by the Central Bank of the UAE,” he wrote, emphasizing the scope of the language.
The relevant provision, Section 62, extends the Central Bank’s authority to cover any technology that “undertakes, offers, issues or facilitates” financial activity, directly or indirectly.
This includes infrastructure providers, API services, wallet developers, analytics platforms and decentralized protocols.
In practice, this means that even companies located outside the UAE, if their products are accessible to UAE residents, can be considered infringing.
Another major change arises from Article 61, which defines advertising, marketing or promotion a financial activity that can be licensed as a regulated activity.
This means that simply sending an email newsletter, hosting a website or even posting a tweet about an unlicensed financial product accessible in the UAE could be treated as a violation of the law.
