Obtaining a Money Transfer License in the United Arab Emirates
The money transfer business in the UAE is growing each year and to offer money transmission services in the United Arab Emirates you need a license. As per the rules and regulations set out by the government of UAE, no company is allowed to offer money transfer services without a license.
UAE Money Transfer License Regulators
If you’re willing to operate as an MSB in the United Arab Emirates, you should first decide which jurisdiction should you locate your business in. Take into consideration your client base, availability of staff, suitable office location, the cost of doing business, and also the legal and regulatory environment of the different jurisdictions.
Following are the three regulatory authorities in UAE:
Central Bank UAE
According to Article 64 of the Decretal Federal Law No. (14):
Licensed Financial Activities may only be carried on, in or from within the State, in accordance with the provisions of this decretal law, and the rules and regulations issued in implementation thereof.
Federal Law No. (14) outlines the financial activities which are required to be licensed and regulated in the United Arab Emirates. In addition to the Central Bank UAE, The Securities and Commodities Authority (SCA) in the country regulates certain financial institutions in the country, like brokerage firms, commodity, asset and advisory management firms. Other licensed financial institutions like banks, currency providers and credit providers are regulated by the Central Bank UAE.
Abu Dhabi Global Market (ADGM)
The Abu Dhabi Global Market (ADGM) is a financial free zone within the UAE. The institution has its own commercial and civil laws and its own regulator, Financial Services Regulatory Authority (FSRA).
Any financial institution willing to set up in ADGM will be licensed and regulated by the FSRA. All firms in ADGM can have 100% foreign ownership and will have to follow rules and regulations similar to those followed in the United Kingdom.
As a money services business operating in ADGM, you will be able to convert currency, transmit money to corporations and individuals across the world. According to ADGM, the following financial activities can be undertaken as an MSB:
(a) Foreign exchange services
(b) Payment services or intermediary payment services via traditional payment methods, via the internet and mobile technology, and by using innovative Fintech solutions.
Dubai International Financial Centre (DIFC)
The Dubai International Financial Centre (DIFC) is another financial free zone in the UAE. All financial institutions looking to establish their business in DIFC are regulated by the Dubai Financial Services Authority (DFSA).
All companies in DIFC can have 100% foreign ownership and the regulatory environment is similar to that of the United Kingdom.
DFSA explains money transmission business as:
Providing money services means providing currency exchange or money transmission. ‘Money transmission’ means:
(a) selling or issuing payment instruments;
(b) selling or issuing stored value; or
(c) receiving money or monetary value for transmission, including electronic transmission, to a location within or outside the DIFC.
Applying for a Money Transfer License in the United Arab Emirates
The application process depends on the jurisdiction you choose. If you’re looking to establish your business in the financial free zones of the country, you will have to apply for a license to the ADGM or DIFC. On the other hand, if you establish a business outside this zone, a license application to the central bank UAE will be compulsory.
Regardless of the jurisdiction you opt for, there are certain aspects that remain the same. All regulators require your business to strictly adhere to KYC, anti-money laundering and counter-terrorism finance requirements. Regulators require your financial statements, business plan/model and a list of directors along with your application. They also require you to have a proper compliance program in place. As part of your licensing application, a thorough background check of the board of directors of the company will also be conducted by the regulators.
The licensing fees and costs depend on the type(s) of financial activities you intend to undertake. Also, every regulator has a different license application fee. Fee structure, as defined by all three regulators, can be found here – Central Bank UAE, DIFC, ADGM.