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A surge in crypto market activity has turned Dubai into a prominent hub, increasing the importance of effective regulations to support a more integrated global environment, according to a joint article by PhD researchers Hassan Amine El Sayed and Fatimah Diouani published in Gulf Today. The researchers noted that rising interest in trading and investment has amplified calls for clear oversight in both the EU and GCC to protect participants while encouraging innovation. Their analysis arrives as the EU moves toward full implementation of its rules in the second half of 2026.
The researchers described how the EU adopted the Markets in Crypto-Assets regulation in 2023 to cover crypto-assets outside existing legislation such as MiFID II. GCC-based crypto-asset service providers must obtain authorisation if they intend to serve EU clients or pursue trading admission under the framework. CASPs face general obligations that include safekeeping of client crypto-assets and funds, complaints-handling procedures, conflict of interest policies, prudential standards and governance arrangements.
Depending on the services offered, the researchers explained that CASPs must also satisfy rules on client due diligence, transparency and prevention of market abuse. The article highlighted substantial penalties for infringements, with fines reaching up to 5 million euros for individuals and 15 million euros for companies. EU authorities may additionally impose measures such as temporary bans or suspension of authorisation, making early compliance steps essential for providers in the GCC.
Regulation across the GCC shares the EU’s focus on investor protection and market integrity yet follows distinct paths in each jurisdiction rather than a single bloc-wide system, the researchers reported. In the United Arab Emirates, federal Cabinet Decision No. 111 of 2022 sets a framework for virtual assets and service providers while Dubai Law No. 4 of 2022 established the Virtual Assets Regulatory Authority, with further oversight from the Abu Dhabi Global Market’s Financial Services Regulatory Authority and the Dubai Financial Services Authority in the Dubai International Financial Centre. Bahrain’s Crypto-Asset Module requires licensing and anti-money laundering compliance for service providers.
Divergence widens among remaining GCC members, the researchers detailed in their Gulf Today article. Saudi Arabia continues without a comprehensive framework governing crypto trading, Qatar confines certain digital asset activities to the Qatar Financial Centre while barring traditional cryptocurrencies such as Bitcoin, and Kuwait prohibits crypto-related activities. Oman is advancing a regulatory structure that prioritises licensing and investor protection measures.
Chainalysis data placed UAE crypto transaction volume above 30 billion dollars between July 2023 and June 2024, positioning the country as the MENA leader and among the world’s higher-ranking markets in adoption. A Forbes assessment from late 2025 found that more than 80 virtual asset service providers had obtained licenses across the UAE’s regulatory bodies. The researchers concluded that companies active in both regions must master the respective requirements for seamless compliance, with potential regulatory convergence offering pathways to expanded cross-border activity.
