Crypto Legal Compliance

Business-focused legal support for crypto & digital asset legal & regulatory compliance in the UAE, helping companies reduce risk and move

Crypto & Digital Asset Regulatory Compliance

Operating a crypto or virtual asset business in the UAE requires a full regulatory compliance framework — AML/KYC, FATF Travel Rule, VARA or DFSA licensing requirements and ongoing regulatory obligations. We build compliant programmes for VASPs, exchanges, custodians and issuers.

In-depth description

We work closely with financial institutions to build and refine their compliance frameworks. Our service is highly customized, focusing on developing, stress-testing, and implementing robust AML/KYC policies and procedures that are practical, effective, and fully compliant with the stringent standards of the UAE Central Bank and FATF.

Scope of work

  • Work closely with financial institutions to build and refine their compliance frameworks.
  • Our scope is highly customized, focusing on developing, stress-testing, and implementing robust AML/KYC policies and procedures that are practical, effective, and fully compliant with UAE Central Bank and FATF standards.

Price range

AED 50,000 – AED 250,000
Cumulative assessment – billed Hourly.

Primary Determinants of Pricing
Regulatory framework (standard company, sensitive industry such as gold trading, real estate or financial services, digital assets licensed service providers, VASP, banking or funds).
Corporate structure, management structure, company size, number of transactions, customer type, existing policies, new policies etc.

Deliverables

  • A bespoke, comprehensive AML/KYC Policy and Procedures Manual.
  • A formal report on compliance gaps and recommendations.

Is your crypto compliance framework fit for UAE regulation?

Does your business handle or custody digital assets for clients?

Businesses that custody or transfer digital assets face UAE AML/KYC obligations. Non-compliance carries severe penalties.

Has your AML policy ever been reviewed against FATF standards?

FATF Travel Rule requirements and risk-based AML frameworks are mandatory for VASPs. Most policies have significant gaps.

Are you applying for a VARA, DFSA, or FSRA licence?

Licensing applications require a fully documented compliance framework. We build it to the standard regulators actually accept.

Has a regulator flagged compliance concerns with your business?

Regulatory inquiries move fast. A proactive compliance review and legal response strategy limits exposure and avoids escalation.

Frequently asked questions

UAE financial institutions need a risk-based AML/CFT framework covering: customer due diligence (CDD), enhanced due diligence for high-risk clients, transaction monitoring, suspicious transaction reporting to UAEFIU, sanctions screening and an internal compliance function. Central Bank and VARA supervise compliance and actively enforce.
The UAE was removed from the FATF grey list in February 2024 and from the EU high-risk list in June 2025, following major regulatory reforms. UAE financial institutions now operate under substantially stronger AML/CFT requirements and face ongoing international peer review. Compliance expectations have risen and are actively enforced.
 
An STR must be filed with the UAE Financial Intelligence Unit (UAEFIU) whenever a financial institution knows, suspects or has reasonable grounds to suspect that a transaction involves proceeds of crime or money laundering. There is no minimum transaction value. Failure to file is an offence; tipping off the customer is also prohibited.
Penalties are severe. Administrative sanctions can reach AED 50 million per violation. Licence suspension or revocation is possible for systematic failures. Personal criminal liability for compliance officers and senior management is available for knowing or negligent AML breaches. The UAE is increasingly using its full enforcement toolkit.

Yes. UAE AML obligations extend to Designated Non-Financial Businesses and Professions (DNFBPs), including lawyers, accountants, real estate agents, trust service providers and dealers in precious metals. Virtual asset service providers face a dedicated regulatory regime under VARA. The scope of AML obligations in the UAE is broad and expanding.

Key contacts:

Romain Astruc

Managing Partner – Generalist, Advisory & Litigation

Mehdi Al Ghafari

Associate – Corporate, Commercial & Litigation

Gabriel Elmarzouki

Associate – Corporate, Commercial & Litigation

Get in touch

Other services you might need

AML/KYC compliance connects to regulatory licensing, corporate governance and the broader financial crime framework for your institution.

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White-Collar & Financial Crimes for Businesses

AML failures often lead to criminal exposure. We represent institutions and individuals in financial crime proceedings.
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Tokenisation of RWA - Legal & Regulatory Structuring

Crypto and tokenisation businesses face the strictest AML expectations. We build the compliance framework before launch.
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WHAT SET US APART

Why ASTRUC & Co

AML/KYC frameworks must satisfy UAE regulators in practice, not just on paper. We design programmes that hold up under inspection.

1.

Regulatory expertise

We develop AML/KYC frameworks meeting the specific requirements of the CBUAE, VARA, DFSA and FSRA – designed to pass inspection, not just satisfy a legal obligation on paper.

2.

Operations-first

Compliance frameworks must work within your operational reality. We design AML/KYC programmes that are proportionate, practical and embedded in your actual business processes.

3.

Cross-border fluency

Financial institutions with operations in the UAE and Europe face overlapping AML/CFT obligations. We design frameworks that satisfy requirements in all relevant

More than legal counsel

With you, all the way

Life in the UAE brings extraordinary opportunities — and equally complex legal realities. Whether you’re relocating your family, navigating a divorce across jurisdictions, or structuring an inheritance that spans continents, you deserve a legal partner who understands both the technicalities and the human side of what you’re going through. At ASTRUC & Co, we treat every client’s situation as if it were our own.

From our offices in Dubai to our network spanning Riyadh, Paris, and Luxembourg, we bring senior-level attention to every matter — personal or financial. We believe the best legal advice is honest, clear, and delivered by someone who genuinely cares about the outcome. That’s why our clients stay with us, and why they come back when life presents its next chapter.

Ready to move forward?

Book a consultation with our team to discuss your situation and explore the right legal and strategic approach for your business.

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Merger and Acquisition
  • Set-up of the Workstreams related to the Transaction
  • Legal Due Diligence
  • Tax Due Diligence
  • Negotiating and Drafting the SPA
  • Assistance related to Conditions Precedents
  • Registration of the Transaction with the Authorities
Private Equity
  • Advisory on PE life cycle from Fund Formation, Capital Deployment, M&A, etc.
  • Advisory on Financing Rounds and Execution
  • Drafting of Prospectus, Investment Case, Risk Warnings and Investment Disclaimers, etc.
  • Drafting of Shareholders Agreements
  • Advisory on Board of Directors Structuring and Execution
  • Drafting of Policies, Charts and other JVAs
  • Litigation/Arbitration
Banking &Finance
  • Banking loan documentation negotiation and review including requested securities
  • Account opening requirements and forms
  • Compliance controls upon onboarding as a bank customer and regular updates to allow flawless funds repatriation
  • Escalation if needed with banking authorities and preparing file for litigation
  • Arabic speaker for immediate translation or intermediation with third parties including local authorities.
Commercial
  • Commercial Agency – Contract Drafting and Litigation
  • Rent-Sales Contract – Contract Drafting, Contract Management and Litigation
  • Logistic Services Contract
  • IT Services Contract
  • Intermediary Contract
  • Other Services Contract
Construction
  • FIDIC Short Form of Contract
  • FIDIC Larger or more complex projects (the Construction Contract)
  • FIDIC Contractor doing the Design (Plant and Design-Build Contract)
  • FIDIC EPC/Turnkey Contract
  • Review of Ad Hoc Contracts
  • Assistance for Management of the Contract
  • Litigation/Arbitration
Employment Relationship
  • Assistance during Recruitment Phase with Executive Search Agents or Recruitment Agency
  • Drafting Offer Letter and Employment Contract
  • Drafting Disciplinary Policy and Documentation
  • Registration of Company with Labour Authorities
  • Registration of Employee with Labour Authorities
  • Assistance During Disciplinary Proceedings
  • Termination Strategy and Execution
  • Litigation Services
HR Strategy – Advisory Services
  • Labour Market Analysis
  • Labour Legislation Memo and Manual
  • Analysis of Remuneration Trends, Structures and Composition
  • Labour Taxation
  • Industry Practice reg. bonus, schedule, overtime, leave, length of service, etc.
Business Set-Up and Maintenance
  • Comparative Study on Options Available
  • Legal Memorandum on Corporate and Tax Laws
  • Set-Up Services (Company, Immigration, Labour, Banking, Tax)
  • Nominee Services (Regulated Activity)
  • Shareholders Agreements
  • Board of Directors Structuring
  • Dissolution, Liquidation, Bankruptcy Proceedings
  • Litigation/Arbitration (Manager or Shareholders Dispute)
  • Redomiciliation
Joint Venture and Investors Relationship
  • Set-up of Joint Venture Company
  • Drafting Joint Venture Agreement
  • Drafting of Prospectus, Investment Case, Risk Warnings and Investment Disclaimers, etc.
  • Drafting of Shareholders Agreements
  • Advisory on Financing Rounds and Execution
  • Advisory on Board of Directors Structuring and Execution
  • Drafting of Policies, Charts and other JVAs
  • Litigation/Arbitration
Expatriation Services
  • Employment Package and Contract Review
  • Wealth Management Advisory
  • Tenancy Opportunities and Contract Advisory
  • Medical Insurance Advisory
  • Banking Advisory
  • School Advisory
  • Logistic Advisory
  • FX Exchange Advisory
Relocation
  • Resignation Strategy
  • Tax Situation Review
  • Logistic Advisory
  • FX Exchange Advisory
  • Administration of the Departure and Legal Representation
Advisory
  • Advisory Services on the Developer (reliability check)
  • Review of Contract with Developer
  • Conveyance of Property and Supervision of the Sales Process
  • Legal Representation for the Purchase/Sales
  • Assistance with Engineers and Contractors
  • Assistance with tenants or holidays home management firm
Litigation
  • Cancellation of Contract
  • Cancellation of Project
  • Disputes regarding Lands
  • Disputes regarding Permits and Licenses
  • Dispute with Engineer or Contractor
Civil Status
  • Amendment of Civil Status (divorced/married) in Home Country
  • Change of Name
  • Transcription of Marriage or Divorce
  • Legalisation Services with Consulate and Embassies
Nationality and Immigration
  • Application for Nationality due to family reasons
  • Coordination Services for Obtaining Nationality based on Investment (more than 40 countries)
  • Immigration Services to Schengen Country (Tourist, Business, Long Term, Residence, Nationality)
  • Immigration Services to the USA, UK, Canada, Australia (Tourist, Business, Long Term, Residence, Nationality)
  • Immigration Services to GCC countries (Tourist, Business, Long Term, Residence, Golden Visa, Nationality)
Succession Planning
  • Overall Estate Planning with Financial and Legal Experts
  • Set-up of Shariah Compliant Foundation or Holding Structure
  • Set-up of Trust (DIFC, UAE, ADGM, Foreign based)
  • Set-up of Holding Structure
  • Set-up of Last Wills in the UAE, Qatar, KSA and various territories, as needed
  • Family Counseling - Mediation of dispute between family members
Inheritance Proceedings
  • In any country where there are assets
  • Court proceedings based on Shariah Law
  • Court proceedings based on Deceased Law
  • Court Proceedings based on Last Will
Crime against the Person and Narcotics
  • Assault, Sexual Abuse, Murder
  • Kidnapping
  • Household Theft
  • Threat, Insult, Defamation, Harassment
  • Social Media Crimes
  • IT Crimes
  • Stealing or Misappropriation of Personal Data
  • Narcotics
Business Crimes
  • AML issues
  • Cryptocurrency and other Investment related Scams
  • Breach of Trust
  • Deception and Fraud
  • Theft of business secrets
  • Insolvency related Crimes
  • Accounting Crimes
  • Interpol
Marriages
  • Marriage between French nationals
  • Marriage involving a French national and a non-French national
  • Marriage involving two persons of the same nationality
  • Marriage involving two persons of different nationality
  • Marriage involving a Muslim
  • Brief on matrimonial regimes and applicable laws
Divorces
  • Divorce between French nationals
  • Divorce involving a French national and a non-French national
  • Divorce involving two persons of the same nationality
  • Divorce involving two persons of different nationality
  • Divorce involving a Muslim
  • Brief on matrimonial regimes and applicable laws