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title: United Arab Emirates — Conduct, Safeguarding & Promotions | World Payments Monitor
canonical: https://payments.gi/jurisdictions/united-arab-emirates/w1b/
publisher: Asymmetric Intelligence

### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-06-27

Onshore conduct and safeguarding flow from the SVF Regulation and RPSCS Regulation, supervised by the CBUAE Consumer Protection function. SVF licensees must protect customer float (segregation / additional capital floor mechanisms), maintain an Additional Capital Float buffer of at least 5% of total customer float, and meet fit-and-proper, residency, risk-management and AML/CFT obligations. Conduct standards include standardized pre-contractual disclosure (Key Facts Statements), fee-change notice rules and complaint-handling, with the Sanadak ombudsman as external escalation.

Standing sub-brief · as of 7 July 2026 75 words · last cycle 2026-09-21

#### Conduct, Safeguarding & Promotions

Stored value facility licensees must protect customer funds through an Additional Capital Float of at least 5% of total customer float, float segregation via escrow or restricted accounts with daily reconciliation, and AED 15 million minimum paid-up capital.

#### Outlook

As CBUAE's expanded 2025 Central Bank Law jurisdiction takes effect toward the 16 September 2026 deadline, safeguarding and conduct obligations for stored value and payment token issuers are expected to tighten further.

Periodic update · new data 2026-09-28

#### Conduct, Safeguarding & Financial Promotions

The CBUAE's Payment Token Services Regulation embeds a clear safeguarding design choice: Dirham Payment Tokens must be fully fiat-reserve backed, while algorithmic stablecoins and privacy tokens are prohibited outright under the framework. This is a monetary-integrity-driven conduct requirement rather than a general restriction on stablecoin product design, and it positions the UAE's approach as comparatively conservative relative to jurisdictions that permit algorithmic stabilisation mechanisms or under-collateralised structures.

A further conduct-relevant development this cycle is the designation of all PTSR Licensees and Registrants as AML Obligors under UAE law. This designation sits at the intersection of conduct and financial-crime compliance; the underlying AML/CFT-regime analysis of what this designation requires in practice is rendered separately by this brief's subscribed financial-crime coverage, and this module carries the designation as a surface fact relevant to the conduct obligations PTSR entities face rather than duplicating that analysis.

Taken together, the full-reserve-backing requirement, the algorithmic-stablecoin prohibition, and the AML Obligor designation form a coherent conduct-and-safeguarding package: PTSR entities face both product-design constraints intended to protect token holders and monetary integrity, and status-based compliance obligations intended to protect the broader financial system.

#### Outlook

Watch for any enforcement action testing the reserve-backing and algorithmic-stablecoin-prohibition requirements as more AED-pegged stablecoins move through the operational-phase pipeline, and for how the AML Obligor designation interacts with the broader UAE AML/CFT guidance tightening tracked elsewhere this cycle.

**Sources and findings (4)**

1. T1 [https://rulebook.centralbank.ae/en/rulebook/stored-value-facilities](https://rulebook.centralbank.ae/en/rulebook/stored-value-facilities) retrieved 2026-06-27
2. T3 [https://www.cryptoverselawyers.io/central-bank-uae-stored-value-facilities-regulation/](https://www.cryptoverselawyers.io/central-bank-uae-stored-value-facilities-regulation/) retrieved 2026-06-27
3. T3 [https://bank-uae.com/uae-banks-customer-rights/](https://bank-uae.com/uae-banks-customer-rights/) retrieved 2026-06-27
4. T1 [https://rulebook.centralbank.ae/en/rulebook/article-13-technology-risk-and-information-security](https://rulebook.centralbank.ae/en/rulebook/article-13-technology-risk-and-information-security) retrieved 2026-06-27
