The UAE is undeniably a global hub for blockchain, fintech, and virtual assets, with major exchanges and protocols such as Binance, ByBit, OKX, Crypto.com, Solana, SUI and Shiba Inu an established presence. Federal, Emirate and Financial Freezone regulatory frameworks all signal a country that is open for business to crypto, which is echoed in political will. But setting up here? That’s a different beast entirely.

Over the past two years at Ape Law, we’ve worked closely with businesses entering the UAE, from participating in the first round of licensing applications with VARA, successfully navigating variations to the ADGM’s laws on behalf of client’s VA businesses, to engaging with Regulators on industry consultations. And in that time, we’ve learned a few things. So has Mari Koval, our go-to expert on start-up, scale up operationalisation  — here are 5 key points in particular, that every founder should keep in mind before taking the plunge.

1. Regulation ≠ Operational Readiness

Just because there is a legal framework for virtual asset businesses does not mean the process of setting up is frictionless.

The single biggest pain point? Banking.

Let’s face it. Banking for crypto businesses globally is difficult, if not impossible. In the UAE, even with regulatory and political buy-in, banks are still extremely risk-averse when it comes to crypto businesses. Which is justifiable, given the tight prudential compliance requirements that they must meet, which keeps the industry safe and consumers funds safe. 

Happily, banking services are available to crypto businesses in the UAE, but the process of successfully obtaining and maintaining banking services is not as easy as you might mistake it to be. Expect to face months of due diligence, comprehensive disclosures and battle through opaque requirements, and, quiet possibly, rejection. And if you do get an account? Expect payments to be stalled, blocked, or rejected —unless you have a direct line to the bank’s compliance team and extremely accurate parameters on transaction allowances. This is not to bemoan banks or their processes. They are a necessary part of BAU and their processes are necessary and justified. However, the disconnect between web3 businesses and banking institutions is apparent in the lack of understanding between one another' s businesses. 

Frustratingly, most banks are in the process of learning and understanding web3 business, which means crypto businesses must be patient and above all, extremely well prepared to explain in granular detail the ins and outs of their business and operations. Some banks are extremely cognizant of the space and working overtime to become knowledgable in the space. For this reason we recommend specific institutions over others. Ultimately, any new market entry should carefully consider core service providers, and above all, banking partners. If you select the wrong banking partner, you could cause undue delay to your set up activity, or  be stuck explaining your entire business model every time you need to process a transaction.

What does this mean for founders? You need a banking strategy from day one. This isn’t just about picking a bank and hoping for the best. You need contingency plans. Fallback banking solutions. Access to alternative providers. The same goes for insurance, recruitment, and compliance infrastructure. These aren’t afterthoughts; they need to be part of your initial market entry strategy.

2. Competition Between UAE Jurisdictions is Real—And It Shapes Your Options

In most countries, there is either a single regulator for virtual assets—MAS in Singapore, the FCA in the UK, the SEC in the US (for better or worse), or none at all. Not so in the UAE. Here, you have multiple jurisdictions competing to attract the best projects.

• ADGM in Abu Dhabi – Institutional, well-established, popular for global players, around since 2018. 

• DIFC in Dubai – Financial hub, but more selective in its crypto engagements, est. 2022. 

• VARA (Dubai-wide regulator) – The newest player, attracting exchanges and infrastructure projects, est. 2023. 

Each of these regulators is open for business, but their actual appetite for risk—and the type of companies they want to license—varies significantly. On paper, you might think you have options. In reality? Some jurisdictions will work for your business model, and some won’t.

Founders need to do more than just skim regulatory brochures and pump rulebooks into ChatGPT for answers.  You need to speak to advisors and projects  that have successfully navigated the process, understand which regulators have granted licenses, and analyze what types of businesses are actually getting through the pipeline. A misstep in choosing jurisdiction can mean months of delays—or even a dead end.

Historically, crypto businesses have played regulatory arbitrage, picking jurisdictions with the least friction. But the UAE is different. Here, the game isn’t about avoiding regulation—it’s about picking the right regulatory home for long-term success.

3. Crypto is Global, But Talent is Local

Crypto exists online—somewhere in and between the primordial soup that is quasi public and private - CT, Discord and Telegram groups that drive the conversation and meta. The markets are 24/7. Decentralized exchanges don’t need headquarters. And yet, when it comes to building a real business, all projects of substance need localised, real-world talent.

This is where the UAE excels. Beyond multiple competing regulatory frameworks, the region has attracted some of the best minds in blockchain—developers, lawyers, tax advisors, compliance specialists, and ecosystem builders. Unlike other jurisdictions where regulators are still catching up, courts and law enforcement here actually understand crypto. That’s a game-changer for dispute resolution and business operations.

Setting up shop here isn’t just about getting licensed—it’s about embedding yourself in a community that is shaping the industry. The businesses that succeed aren’t just the ones that incorporate in the UAE. They’re the ones that commit to building here.

4. Timeframes & Migration Planning: Why Moving Your Team Too Soon is a Costly Mistake

A common mistake companies make is relocating key personnel too early to manage operations, partnerships, and scaling. Unlike transactional markets in the US, EU, UK, or AU, success in the UAE is built on relationships, trust, and long-term credibility. It takes years, not months, to integrate and close major deals.

Many firms assume that relocating an executive will accelerate their growth. The reality? Without the right groundwork - strategic networking for a period of time pre-entry, hands-on ecosystem integration experience, and proven localized operational structures - even the most seasoned project struggle to gain traction, let alone material investment, which many come for, and few obtain.  

A well-structured Market Entry & Migration Plan should include:

• Partnering with established local players – Engaging ecosystem players who have established market relationships shortens timelines and avoids costly trial and error. Vs trying to build everything from scratch, it will take years.

• Aligning with government & industry initiatives – Strategic positioning builds credibility and accelerates approvals.

• Setting realistic timelines and operational milestones – Some processes, like banking, compliance, and licensing may take longer than expected and require contingency and localized planning. 

Expectation: "We’ll set up operations and scale within a few months."
Reality: It takes 1+ year to establish a strong foothold.

5. The Real Cost of Establishment & Scaling: How Much is It Really Going to Cost? 

The other major mistake companies make is underestimating the actual cost of doing business in the UAE. While the region offers compelling advantages among GCC countries, the upfront and ongoing costs of market entry and operations are often underestimated by new businesses.

A proper Viability Study should go beyond basic incorporation fees and consider:

• Company Establishment & Licensing – Free zone vs. mainland setup, regulatory approvals, and compliance costs vary greatly.

• Hiring & Talent Strategy – Building an effective local team is critical, but top-tier talent comes at a premium.

• Partnership & Deal Structuring – Business development here is relationship-driven, and deals often require significant upfront time investment in networking, sponsorships, and local engagement.

Expectation: "We can replicate our home market’s cost structure and business model here."
Reality: The UAE operates on a different economic and business logic. A one-size-fits-all approach doesn’t work—companies must localize their strategy, pricing, and cost allocations to align with how business is done here.

Final Takeaways

Setting up in the UAE is an incredible opportunity—but it is not plug and play. It’s not just about ticking regulatory boxes. It’s about:

• Navigating the operational hurdles, especially banking.

• Choosing the right jurisdiction based on real-world licensing outcomes.

• Plugging into the local talent ecosystem to actually build and scale.

• Building relationships 

For founders considering expansion into the UAE, the key message is this: regulatory clarity is just the beginning. The real challenge—and opportunity—comes from executing on the ground. Ultimately, this market rewards those who do it right.

If you are considering a move to the UAE and want real world implementation  insight paired with legal advice, licensing support and regulatory strategy, let’s talk.

Written in collaboration with Marie Koval.