Legal Regulation and Control in the Sphere of Virtual Asset Circulation in the UAE

The paper examines the legal regulation and control of virtual asset circulation in the United Arab Emirates (UAE). The issuance and circulation of virtual assets in the UAE are governed at three levels — federal, emirate-specific, and within free financial zones, where common law applies. It is noted that UAE legislation does not use the term «cryptocurrency»: the basic category is «virtual asset», which is not classified as money, with a special subtype being a payment token, which is subject to oversight by the Central Bank of the UAE. The study dissects the division of powers among five regulatory bodies based on territorial and functional criteria. Control procedures are systematized along a stage-based axis, distinguishing between preliminary control (licensing, recognition of assets permissible for circulation, approval of issuance documentation) and subsequent control (inspections, document requests, reporting, anti-money laundering supervision). The author concludes that the control system in the UAE virtual asset market is polycentric and gives rise to risks of regulatory arbitrage, while legislative changes in 2025–2026 signal a trend towards centralizing control powers at the federal level.