Stable Value, Unstable Assumptions: What Every UAE Business Needs to Know About Stablecoins

7 min 33 sec October 15, 2026 (Edited)

Written by

Max Davis

Legal Director

m.davis@tamimi.com View LinkedIn Profile

Many sophisticated professionals think their business does not touch digital assets. But if a company sends or receives cross-border payments, manages a payroll with international staff, settles trade-finance transactions, engages with a supply chain, holds treasury reserves, or operates within any sector where a counterparty has offered to pay in digital currency, stablecoins are already part of their commercial landscape.

What is a stablecoin?

A stablecoin is a digital token designed to maintain a fixed value relative to a reference asset, typically a fiat currency such as the US dollar or the UAE dirham. Each token is backed by reserves of the reference asset held by the issuer.

The global stablecoin market surpassed USD 300 billion in total supply by late 2025, growing 49% in that year alone as regulatory clarity and institutional adoption accelerated worldwide. These are no longer niche instruments.

Which stablecoins are authorised for use in the UAE?

The UAE operates a sophisticated multi-regulator framework for stablecoin authorisation, and the applicable regime depends on where the activity takes place.

Onshore, the Central Bank of the UAE has exclusive authority over any stablecoin pegged to the Emirati dirham. There are currently three AED-backed stablecoins with regulatory approval: AE Coin, Zand AED, and DDSC. Rakbank has also obtained in principle approval to launch its own AED-backed stablecoin.

For non-dirham stablecoins used in commercial activity, the Virtual Assets Regulatory Authority (VARA) regulates their issuance and trading in Dubai as fiat-referenced virtual assets. It requires fully reserved backing, whitepaper disclosures, and ongoing governance obligations.

Within the Dubai International Financial Centre (DIFC), the Dubai Financial Services Authority (DFSA) approved Circle’s USDC and EURC as recognised crypto tokens in February 2025. Ripple’s stablecoin, RLUSD, was recognised by the DFSA in June 2025, and Ripple became the first blockchain-enabled payments provider in the DIFC in March 2025.

Within the Abu Dhabi Global Market (ADGM), the Financial Services Regulatory Authority (FSRA) regulates stablecoin issuance as a money service, requiring full one-to-one fiat backing. In addition to Circle’s USDC, Tether’s USDT, and Ripple’s RLUSD, the FSRA has also licensed USDL and USDP (both Paxos stablecoins, with USDL-generating yield) and Universal Digital Intl’s USDU. Only tokens on the FSRA’s accepted list may be used by ADGM-regulated firms.

Algorithmic stablecoins and privacy-preserving tokens are prohibited across all three frameworks.

Where are stablecoins being used in the UAE?

The UAE is among the world’s leading stablecoin jurisdictions, and the commercial applications are already operating across multiple sectors.

Remittances and workforce payments

With approximately 90% of the UAE’s population comprising expatriates, the country ranks as one of the world’s largest remittance senders. Stablecoins reduce the cost of those transfers by around 40% compared to traditional channels, and settlement time drops from an average of five days via legacy correspondent banking to approximately 20 minutes. For businesses managing large expatriate workforces, stablecoin-denominated payroll processing and remittance infrastructure represent a material operational advantage.

Trade finance and cross-border settlement

The volume of stablecoins traded in the UAE across trade finance, remittances, and business-to-business settlement surged more than 40% year-on-year in 2025. UAE trading firms, logistics operators, and commodity houses are using stablecoins to settle invoices across borders, manage liquidity, and reduce counterparty risk in global supply chains. For businesses operating across Asia and Africa, the ability to move value at any hour without correspondent banking delays is commercially transformative.

Retail and fuel payments

ADNOC Distribution, the UAE’s largest fuel retailer, has pioneered the use of AE Coin. By the end of 2025, AE Coin was accepted at 980 service stations across the UAE, Saudi Arabia, and Egypt. Beyond fuel, stablecoin payments are now accepted for certain government services, flight tickets, and hospitality venues.

Treasury management and corporate finance

Multinationals and large corporates are deploying stablecoin-denominated liquidity pools for real-time foreign-exchange netting and inter-company settlements. Tokenised money-market funds backed by short-term government securities and denominated in stablecoins have attracted billions in institutional capital in 2026, offering treasury teams liquidity, yield, and programmability that traditional bank deposits cannot match.

Real estate and property transactions

Stablecoin settlement is increasingly being used in high-value property transactions within the UAE, particularly involving international buyers, providing instantaneous cross-border transfers of funds without the delays associated with wire transfers.

What happens when stablecoins become the subject of disputes?

The commercial adoption of stablecoins creates a new category of legal exposure that most businesses are only beginning to understand. Disputes involving stablecoins arise in several contexts:

• failed commercial transactions where payment was made in stablecoins but the underlying contract is contested;
• fraud, misappropriation, or theft, where stablecoins represent the proceeds;
• insolvency proceedings where a company’s stablecoin holdings must be recovered for creditors; and
• regulatory enforcement actions where stablecoin wallets are frozen, sometimes affecting innocent parties.

The last of these is particularly important. Unlike decentralised cryptocurrencies such as Bitcoin, stablecoins are issued by centralised entities that retain contractual and technical powers to freeze wallet addresses. Tether has blacklisted over 7,000 addresses globally, with a combined frozen balance of approximately USD 3.29 billion. Circle has taken a more reactive approach, generally requiring a formal court order or sanctions designation before acting, but has nonetheless frozen approximately USD 110 million across its blacklisted addresses.

Freezes do not only affect wrongdoers. Innocent commercial counterparties can find their stablecoin balances immobilised because funds received from a third party were subsequently linked — several transactions removed — to a sanctioned address or a theft event. A business holding a stablecoin received from a counterparty may be affected because that counterparty received funds from an intermediary linked to illicit activity, without any knowledge or involvement on the business’s part.

For businesses in the UAE, understanding what rights, remedies, and options are available where stablecoin balances are at issue, as well as who to contact and how to move quickly, is becoming increasingly important.

How to freeze: The available pathways

Understanding that stablecoins can be frozen is only the starting point. Knowing how to achieve a freeze, and which route to take, is where specialist legal advice becomes decisive. There are four principal pathways, each suited to different circumstances, and which may operate in tandem.

1. Criminal complaints and law enforcement engagement

The most direct route where criminal conduct is apparent is a complaint to the relevant law enforcement authority, which can then engage the issuer through established channels. A victim engaging UAE law enforcement, or a practitioner with established relationships across jurisdictions, can access this infrastructure directly.

2. Regulatory engagement

Where the dispute involves a licensed virtual-asset service provider operating under the supervision of the Central Bank of the UAE, VARA, the DFSA, or the FSRA, regulatory channels provide an additional avenue.

Licensed custodians and exchanges are subject to anti-money laundering and asset-tracing obligations; they can be compelled to freeze customer accounts or report transaction flows as part of a regulatory enforcement action. Businesses operating within the UAE’s regulated digital-asset ecosystem have access to a supervisory infrastructure that can respond to properly evidenced complaints with powers that have significant scope and reach.

3. Direct engagement with the issuer

For some issuers, a direct approach is available where a victim can demonstrate the factual basis for a freeze clearly and quickly. This route works best where:

• blockchain forensics clearly identify the suspect wallet;
• the connection to the fraud or theft is traceable on chain; and
• the request is made before the funds are moved through mixers or converted into other assets.

Legal representation with experience of the issuer’s requirements and communication protocols is essential. Compliance teams process high volumes of requests; a well-prepared, evidenced submission materially improves the prospects of rapid action.

4. Court orders and injunctive relief

Where speed is critical and the dispute is civil rather than criminal, without-notice freezing orders obtained through the DIFC and ADGM courts (or equivalent relief available in the onshore courts) can provide the legal basis for compelling a custodian or exchange to preserve assets.

Key takeaways

The sectors most exposed to stablecoin disputes include financial services, real estate, commodities trading, logistics, hospitality, and any business operating across the UAE-Asia or UAE-Africa corridors. If a business accepts stablecoin payments, holds stablecoin reserves, or has counterparties who settle in stablecoins, the following steps warrant attention.

• Ensure commercial contracts address stablecoin payments expressly, including what happens in the event of a freeze, a disputed transfer, or a regulatory enforcement action. Do not assume that accepting a stablecoin payment creates the same rights and remedies as receiving a wire transfer.
• Understand which stablecoins your counterparties are using and whether they are authorised under the applicable UAE regime. Receiving payment in an unrecognised token creates regulatory as well as commercial risk.
• If a stablecoin balance is frozen or a transaction is disputed, act immediately. The chain of on-chain evidence is time-sensitive, and early legal intervention significantly improves the prospects of recovery.
• Build relationships with specialist advisers in advance — before a dispute arises — as those advisers may need to act quickly. Advisers with a sound understanding of how digital assets interact with day-to-day business operations will make clearer, more persuasive, and more effective submissions and requests for assistance to token issuers, law enforcement, or regulators.