Jurisdictions

UAE-built. Globally engaged.

CASA was built in the United Arab Emirates and the UAE remains the centre of our practice. We extend across Europe, the United Kingdom, Asia, Switzerland, the Americas and the major offshore international financial centres — through resident practice, named partner networks, and continuous regulatory monitoring.

How we frame coverage

Three tiers of engagement.

We are explicit about how we work in each jurisdiction. The right answer for an institutional client is not "we do everything everywhere" — it is a clear depth claim, calibrated to what the engagement actually requires.

Resident practice

Senior CASA team based in-jurisdiction, working directly on regulator-facing engagements. Today: the United Arab Emirates.

Network partners

Co-delivery with named local counsel and specialist advisory firms in our partner panel — under documented terms, with CASA leading the engagement architecture.

Active monitoring

Regulatory horizon-scanning and policy intelligence in jurisdictions we track but do not transact in directly. Useful for comparative work and for clients evaluating future expansion.

United Arab Emirates · Resident practice

The centre of our practice — the full federal and free-zone perimeter.

VARA — Virtual Assets Regulatory Authority (Dubai, ex-DIFC)

The dedicated virtual asset regulator for Dubai. Seven activity rulebooks under Version 2.0 (May 2025): Advisory, Broker-Dealer, Custody, Exchange, Lending and Borrowing, Management and Investment, Transfer and Settlement. Marketing Regulations and Compliance and Risk Management Rulebook apply across all categories.

Where we engageEnd-to-end: licensing pathway, application drafting, RI preparation, post-licence supervision, mock inspections.

ADGM FSRA + Registration Authority (Abu Dhabi)

FSRA Category 4 for advisory firms with a Virtual Asset Application Form against the Accepted Virtual Assets list. Common-law framework; English-language. RA commercial licence for unregulated services.

Where we engageLicence applications, FSRA Q&A, RI mock interviews, RA commercial set-up, post-authorisation supervisory engagement.

DIFC DFSA — Dubai Financial Services Authority

Crypto Token regime (as amended 12 January 2026). Firm-as-gatekeeper suitability standard with a written Token Suitability Methodology. Category 4 for advisory firms.

Where we engageDFSA Category 4 applications, Token Suitability Methodology design, per-token assessment files.

SCA / CMA — federal layer

Cabinet Decision 111/2022 empowered the Securities and Commodities Authority. Federal Decree-Law 33/2025 establishes the Capital Market Authority (CMA) as successor with explicit virtual asset perimeter and extraterritorial reach.

Where we engageFederal-perimeter diagnostics, Cabinet Resolution 112/2022 reach analysis, CMA implementing-regulation monitoring.

European Union & EEA · Network partners

MiCA-anchored, with the PSD2 / PSD3 + EMI overlay and the MiFID II carve-out.

MiCA / MiCAR — Markets in Crypto-Assets Regulation

EU's unified regime for crypto-asset services. Stablecoin titles (ART, EMT) live since 30 June 2024; full CASP regime live 30 December 2024. Transitional grandfathering ends 1 July 2026 — earlier in several member states. Ten passportable CASP services under one authorisation.

Where we engageCASP authorisation strategy, NCA selection, white paper drafting, governance and AML/CFT framework build, in partnership with EU counsel.

PSD2 → PSD3 / PSR — payments and EMI overlay

Provisional political agreement on PSD3 reached November 2025; texts published April 2026; entry-into-force expected 2027 with a 21-month transition. PI and EMI licences will merge. Critical interim: from 2 March 2026, EMT transactions that qualify as payment services must be conducted by a PI/EMI alongside the MiCA CASP authorisation.

Where we engageEMI licensing strategy for EMT-issuing CASPs, PI/EMI gap assessments, MiCA-EMI dual-stack governance design.

MiFID II — the financial-instruments perimeter

Crypto-assets that qualify as financial instruments (most security tokens, certain hybrid tokens) sit outside MiCA and inside MiFID II. ESMA's 2025 guidelines on the qualification of crypto-assets are the operative reference. MiFID firms can offer crypto-asset services by notification rather than full CASP authorisation.

Where we engageToken-classification assessments, MiCA-vs-MiFID II perimeter analysis, MiFID notification strategy.

National Competent Authorities

Active engagement supported through partner networks in BaFin (Germany), AMF / ACPR (France), CSSF (Luxembourg), MFSA (Malta), CySEC (Cyprus), Central Bank of Ireland and others. NCA selection is a structural decision — fees, supervisory style and timeline differ materially.

Where we engageNCA shortlisting, application support and post-authorisation supervisory engagement via local counsel.

United Kingdom · Network partners

From the MLR cryptoasset registration regime to the FSMA 2000 (Cryptoassets) authorisation regime.

FCA — Financial Conduct Authority

Today: Money Laundering Regulations cryptoasset registration plus the financial-promotion regime. Forward: FSMA 2000 (Cryptoassets) Regulations 2026 made 4 February 2026 — authorisation gateway opens 30 September 2026, application window to 28 February 2027, regime live 25 October 2027. New regulated activities cover stablecoin issuance, safeguarding, arranging safeguarding and operating a qualifying trading platform. No automatic conversion from MLR registration.

Where we engageMLR registration, financial-promotion regime, transition planning to the FSMA 2026 regime, in partnership with UK counsel.

Asia-Pacific · Network partners

Singapore MAS and Hong Kong SFC — the two anchor regimes for institutional crypto in APAC.

Singapore MAS — Monetary Authority of Singapore

Two-track regime: Payment Services Act for Digital Payment Token services serving Singapore, and FSMA 2022 Part 9 Digital Token Service Provider regime (live 30 June 2025) for Singapore-incorporated entities serving overseas only. Capital Markets Services licence applies for tokenised capital-markets products. S$250k base capital baseline for DTSP.

Where we engagePSA / DTSP / CMS pathway selection, application strategy and supervisory engagement via Singapore counsel.

Hong Kong SFC — Securities and Futures Commission

VATP regime live; twelve licensed VATPs as of February 2026. November 2025 circulars expanded permitted products (tokenised securities, HKMA-licensed stablecoins) and introduced shared global liquidity with affiliates. 2026 legislation planned for virtual-asset dealers and custodians (separate licences).

Where we engageVATP application strategy and ongoing supervisory engagement via Hong Kong counsel.

Switzerland · Network partners

FINMA's DLT framework and the new Payment-Institution / Crypto-Institution categories.

FINMA — Swiss Financial Market Supervisory Authority

DLT Act framework (DLT trading facility plus tokenised uncertificated securities). October 2025 consultation introduces two new authorisation categories — Payment Institution and Crypto-Institution — with stablecoin issuance reserved to Payment Institutions. SDX is the live licensed DLT financial-market infrastructure.

Where we engageFINMA pathway selection, DLT Act applicability analysis and supervisory engagement via Swiss counsel.

United States · Active monitoring

A federal-plus-state landscape that we track and reach through US-licensed counsel partners.

FinCEN MSB · NYDFS BitLicense · Wyoming SPDI · State MTLs

Federal AML registration via FinCEN; state-by-state Money Transmitter Licences; the NYDFS BitLicense (23 NYCRR Part 200, the costliest US regime); the Wyoming SPDI charter (US$5m statutory minimum, with potential Federal Reserve master account access). California Digital Financial Assets Law compliance deadline 1 July 2026. The SEC / CFTC perimeter remains in flux post-GENIUS Act.

Where we engageStrategy and structuring with named US-licensed counsel — we do not directly hold US licences. Honest scope: federal MSB and selected state MTL strategy in partnership with US counsel.

Offshore international financial centres · Active monitoring

Bermuda, BVI, Cayman, Gibraltar — for token issuers, fund vehicles and custodian structures.

Bermuda — Digital Asset Business Act

BMA-tiered regime: sandbox to Class F / M licences, with strong code-of-practice depth. A credible jurisdiction for tokenisation issuers and digital-asset business platforms.

Where we engagePathway analysis and structuring via Bermuda counsel.

BVI VASP Act 2022

Live since February 2023. Exchange and custody activities captured; certain token issuance and tech-only models often outside scope. Lower entry friction than the Bermuda or Cayman regimes.

Where we engageScope analysis and application support via BVI counsel.

Cayman VASP regime

CIMA registration vs. licensing tiers. April 2025 amendment carved out tokenised funds. Popular for foundation-company token issuers and offshore fund vehicles.

Where we engagePathway selection and structuring via Cayman counsel.

Gibraltar DLT framework

GFSC's principles-based DLT regime — one of the earliest comprehensive frameworks in the market, still relevant for selected use-cases.

Where we engagePathway analysis via Gibraltar counsel.

Across every regime

The cross-cutting work runs in every jurisdiction.

FATF Travel Rule

Recommendation 16 implementation across VARA, MiCA, FCA, MAS, SFC, FINMA and the offshore IFCs. Operating model, message routing, exception handling, breach reporting.

Sanctions and adverse-media

UN, OFAC, EU, UK and UAE-tier list management. Productised re-screening cycles. Cross-jurisdictional escalation playbooks.

Data protection

UAE PDPL, DIFC DPL, ADGM DPR, GDPR, UK Data Protection Act, PDPA (Singapore), PDPO (Hong Kong) — calibrated to the firm's operating perimeter.

Building across multiple jurisdictions?

A short note about your firm and the perimeter you are working across is enough. We respond with where the work usually starts and which of our partners we would bring in — not a generic capabilities deck.

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