The Retail Payment Services and Card Schemes Regulation covers activities such as payment account issuance, payment instrument issuance, merchant acquiring, payment aggregation, domestic and cross-border fund transfers, payment initiation and payment account information services, together with card scheme operation. Issuing or operating a stored value facility is regulated separately, and payment token services have their own regulation. Whether a particular model is caught depends on how funds flow and who holds them. Some activities may be exempt or fall outside the perimeter, but that requires careful analysis against the current rules and the 2025 Central Bank law.

A stored value facility is broadly a product or arrangement where a customer pays money that is stored as value, such as a wallet balance or prepaid card, which can then be used to pay for goods or services or transferred. Issuing or operating such a facility in the UAE mainland generally requires a CBUAE licence, subject to limited exceptions, for example certain single-purpose or closed-loop facilities. Licensees must safeguard customer funds and meet capital, governance and anti-money laundering requirements. Loyalty schemes and marketplace balances can sometimes amount to stored value, so we review each model against the definitions.

Federal Decree-Law No. 6 of 2025 replaced the earlier Central Bank law and updated the framework for licensed financial institutions and related activities. It broadened the scope of activities and persons that may require licensing and strengthened supervisory and enforcement powers, with a transition period for existing businesses that ended in September 2026. Firms that rely on informal assumptions about being outside the perimeter, or that provide technology closely linked to regulated payment services, should review their position now. We help clients assess exposure and plan licensing, restructuring or partnership arrangements in line with the current law.

Money sent to Bangladesh must arrive through channels that Bangladesh Bank permits, usually a Bangladeshi bank or a licensed mobile financial service provider that has a formal arrangement with a foreign exchange house or remittance company. A UAE wallet therefore needs its own UAE licence for cross-border transfers, or a partnership with a licensed UAE institution, and a lawful connection to a Bangladeshi payout partner. Settlement, foreign exchange conversion, compliance checks and reporting must work on both sides. We review the UAE structure and the Bangladesh arrangements together, so the corridor is lawful from end to end.

A Bangladeshi provider can participate in the UAE market, but it would usually do so through partnership with a licensed UAE institution, through a UAE subsidiary that obtains its own licence, or through arrangements with exchange houses for inbound remittances. Its own licence in Bangladesh does not authorise payment services in the UAE. Investment abroad by a Bangladeshi company generally requires Bangladesh Bank approval, and the provider must consider its home licence conditions and group supervision. We advise on the options, the approvals required in both countries and the agreements that make the partnership work in practice.

Capital requirements depend on the licence category and the scale of the business, and the CBUAE may require additional amounts based on risk, volume or other factors. Stored value facility issuers and retail payment service providers face different requirements, and payment token services carry their own. Capital is separate from safeguarding: customer funds must be protected through segregated accounts or other approved methods and cannot be treated as the firm's working capital. Because the rules are updated, we check current requirements for the relevant category and help clients plan funding before they apply.

The Payment Token Services Regulation sets conditions for payment tokens in the UAE mainland. In broad terms, only licensed dirham-backed payment tokens may be used for payments for goods and services in the mainland, with limited exceptions for some foreign payment tokens in particular circumstances such as virtual asset purchases. Algorithmic stablecoins and privacy tokens are prohibited. Firms that wish to issue, convert, custody or transfer payment tokens may need specific authorisation. For Bangladesh-linked flows, the restrictive Bangladesh position on virtual currencies must also be considered. We review the model against both sets of rules.

CBUAE-licensed firms must comply with UAE federal anti-money laundering and counter-terrorist financing law and CBUAE guidance, including enterprise-wide risk assessments, customer due diligence, sanctions screening, transaction monitoring, record keeping, staff training and suspicious transaction reporting to the UAE Financial Intelligence Unit. Cross-border transfers carry information requirements for originators and beneficiaries. Remittance corridors such as the UAE to Bangladesh route need controls that address structuring, use of informal channels and third-party funding. In Bangladesh, payout partners have their own reporting duties to the Bangladesh Financial Intelligence Unit. We help align controls on both sides.