As CARF regulations continue to reshape the global crypto landscape, Dubai finds itself at a pivotal point, where it must make tough decisions. Once considered the go-to exit point for crypto whales, the UAE’s crypto-friendly banks are now facing increasing pressure to comply with stricter financial rules. Crypto whales looking to cash out into U.S. dollars or other fiat currencies can no longer rely on the smooth banking processes as they once did. Banks like Emirates NBD, Dubai Islamic Bank, EmiraTrust Bank, and Mashreq are tightening their procedures, requiring more detailed paperwork and scrutinizing transactions, especially those above a specific dollar amount equivalent to crypto. As these compliance rules evolve, the big question is: Is Dubai still the best place to exit crypto, or have its once reliable banks become just another obstacle for those trying to get out of the digital asset game?
CARF regulations and Dubai’s role
CARF (Crypto-Asset Reporting Framework) is a global financial body established to shed light on the dark corners of the crypto world. The OECD developed the body and aims to clarify crypto transactions by requiring crypto financial institutions, such as some banks in the UAE, and crypto service providers to report information on crypto access proceedings to tax authorities.
Hence, making crypto as transparent as banks currently handle fiat aligns with CARF compliance standards. Crypto exchanges and regulators in the UAE will now be required to conduct detailed KYC for their clients. Secondly, they will be required to track crypto transactions and holdings. Thirdly, the data they have collected must be submitted to the UAE’s authorities.
Dubai plans to start implementing CARF policies in 2027 and to conduct its first automatic data exchanges in 2028. Major financial institutions like Emirates NBD, Dubai Islamic Bank, and EmiraTrustGroup’s Emiratrust Bank are rushing to adapt to these new CARF regulations while maintaining service accessibility for crypto clients who view Dubai as a crypto offramping region, integral to Dubai’s crypto offramping strategies.
However, under CARF regulations, the framework mandates that UAE based crypto platforms report only on account holders who are tax residents abroad; UAE resident investors are not subject to outbound reporting.
Challenges to crypto whales
With these new CARF regulations now in effect in Dubai, persons with large amounts of crypto in cold wallets, entities that obtained crypto from mines that were long closed, or those who obtained crypto as inheritance, face significant challenges. People in crypto forums call such people crypto whales. Dubai has been a sweet spot for them because it is a tourist hub and centrally located in the Middle East. In addition, Dubai did not charge tax on crypto. However, under these new CARF regulations, crypto whales are required to provide comprehensive source-of-funds documentation, detailed transaction histories, and a clear explanation of their wealth accumulation. The challenge is that some of this paperwork can take time to process and obtain accreditation. As a result, a process that now takes just minutes may take up to a month or more for verification. Secondly, some of the paperwork may seem impossible to obtain because some old crypto mines have been closed, and a banking institution asking for it is like looking for a needle in a haystack. Furthermore, failure to provide adequate documentation can result in frozen funds or suspended accounts while investigations are conducted.
Role of Dubai Institution in Crypto offramping
Most traditional banks are still not very crypto friendly, however, with the right documentation and source of funding proof, banks are warming up to more crypto investors. But still, some banks are popular with people looking to offramp, we could refer to them as crypto friendly banks anyway.
First Abu Dhabi Bank
The institution offers a range of crypto related services to its clients, including blockchain and digital-focused packages. The packages are programmable payments via JPM Coin for automated, event-triggered transactions. In addition, the bank offers cross border payments on the blockchain through J.P. Morgan’s coin systems and a nationwide blockchain trade finance platform. The bank has also made news, saying it will partner with Libre Capital on blockchain powered, collateralized lending using tokenized real-world assets, enabling stablecoin loans backed by high-quality funds, as reported on Coindesk.
Dubai Commercial Bank
Dubai Commercial Bank has its client base planted in institutions and virtual asset service providers. These VASPS, in turn, manage clients and ensure they meet VARA/CBUAE regulations. The bank has integrated with JPMorgan’s Knexys link for blockchain based account validation and participation in the UAE KYC Blockchain Platform for secure onboarding. As reported by Norbloc
EmiraTrust Bank
EmiraTrust Bank, part of the EmiraTrustGroup, makes converting cryptocurrencies into US dollars or AED easy and hassle free. You can deposit your crypto into an account, where their banking partner quickly converts it to cash. The bank will then load that money onto your debit card for everyday spending, whether you’re shopping online or at your favorite store. It’s a simple way to turn digital assets into real world cash and spend it just like you would with any standard debit card.
Dubai future as a crypto hub
Dubai’s dedication to complying with the Cryptocurrency Asset Regulatory Framework (CARF) and its alignment with international standards position it favorably for long term sustainability, even amid increasingly stringent regulations. With the implementation of CARF scheduled for 2027 and the first information exchanges set for 2028, Dubai’s evolving crypto regulations reflect a careful attempt to balance innovation with transparency, according to Ledger Insights. The UAE’s removal from the Financial Action Task Force’s (FATF) grey list in 2024 and its exclusion from the European Union’s high risk list in 2025 underscore its growing regulatory credibility, which enhances its competitive edge.
Compared to other regional competitors, Dubai holds certain distinct advantages. Singapore, for instance, has introduced strict retail protections and mandatory licensing by mid 2025, along with bans on crypto lending and staking for retail investors. Switzerland is also moving forward with the implementation of CARF beginning in January 2026, supported by automatic tax data exchanges across 74 countries. However, Dubai’s attractiveness is amplified by its policy of zero personal income tax, combined with a $2 billion institutional investment in Binance and its status as a home to over 1,800 crypto companies employing more than 8,600 people, as noted by Ledger Insights.
Although recent UAE regulations have placed restrictions on privacy coins and introduced stricter anti money laundering (AML) protocols, Dubai’s future in the crypto space remains promising. The city is positioning itself as a hub that emphasizes compliance rather than as a regulatory haven. With strong institutional support and clear regulatory frameworks, Dubai appears poised to continue attracting individuals and institutions seeking legitimate crypto opportunities, especially those who prioritize transparency and legitimacy over anonymity.
