TLP Advisors

This month, @Bybit_Official put a @SpaceX IPO on-chain — days after @binance wired AED into a UAE bank, and weeks after @cryptocom cleared crypto to pay Dubai government fees. @Bybit_Official's IPO Express opens tokenized subscriptions at the offering price, starting with @SpaceX before public trading begins. @binance's ramp runs directly through @OfficialADCB: zero deposit fees, same-day settlement, no third-party processor. @cryptocom is the first VASP licensed by the @centralbankuae under a Stored Value Facility, funding payments in crypto and settling in dirhams. None of this would have been possible without the regulatory groundwork the UAE has spent years putting in place. 𝐖𝐡𝐞𝐧 𝐭𝐡𝐞 𝐰𝐨𝐫𝐥𝐝'𝐬 𝐥𝐚𝐫𝐠𝐞𝐬𝐭 𝐩𝐥𝐚𝐭𝐟𝐨𝐫𝐦𝐬 𝐤𝐞𝐞𝐩 𝐜𝐨𝐦𝐦𝐢𝐭𝐭𝐢𝐧𝐠 𝐫𝐞𝐚𝐥 𝐩𝐫𝐨𝐝𝐮𝐜𝐭𝐬 𝐭𝐨 𝐚 𝐬𝐢𝐧𝐠𝐥𝐞 𝐣𝐮𝐫𝐢𝐬𝐝𝐢𝐜𝐭𝐢𝐨𝐧, 𝐭𝐡𝐚𝐭 𝐢𝐬 𝐚 𝐯𝐨𝐭𝐞 𝐨𝐟 𝐜𝐨𝐧𝐟𝐢𝐝𝐞𝐧𝐜𝐞 𝐧𝐨 𝐩𝐫𝐞𝐬𝐬 𝐫𝐞𝐥𝐞𝐚𝐬𝐞 𝐜𝐚𝐧 𝐦𝐚𝐧𝐮𝐟𝐚𝐜𝐭𝐮𝐫𝐞. 👉@adbc_ae #UAEForDigitalAssets

🚨 The SEC and CFTC have issued joint digital asset guidance - introducing, for the first time, a formal token taxonomy. Key takeaways: • Clear classification framework – Digital Commodities → not securities – Digital Collectibles (NFTs) → not securities – Digital Tools (utility tokens) → not securities – Payment Stablecoins → not securities – Digital Securities → remain under SEC • Lifecycle recognition “Investment contracts can come to an end.” → Tokens may transition out of securities status as networks decentralize. • Core network activities clarified Staking, mining, airdrops, wrapping → not securities transactions • Startup relief incoming A proposed safe harbor (up to $5M over 4 years) signals a shift toward capital formation, not enforcement. Source: sec.gov/files/33-11412…

The UAE Central Bank has recently issued FAQs in respect of Federal Decree-Law No. 6 of 2025 (the “Central Bank Law”). Of particular relevance to market participants is the clarification provided on Article 62, which has been the subject of interpretative uncertainty, especially given the breadth of the phrase “facilitating, whether directly or indirectly”. In its response, the CBUAE has provided helpful guidance which materially narrows the perceived scope of Article 62. In particular, the CBUAE has clarified that Article 62 is not intended to regulate, license, or prohibit technology service providers solely by virtue of their role as providers of software, infrastructure, or other technical solutions. Such entities fall outside the Central Bank’s licensing and supervisory perimeter, unless they themselves undertake, purport to undertake, or otherwise facilitate regulated financial activities (as defined under Article 61), such as the provision of payment services, wallet services, or stored value facilities, whether directly or indirectly. Importantly, the CBUAE further confirms that where a technology service provider is acting exclusively in support of a licensed financial institution—by providing software, infrastructure, or technological solutions—such activities will not, in and of themselves, be regarded as “practising”, “offering”, “issuing” or “facilitating” a regulated financial activity for the purposes of Article 62. This clarification provides meaningful comfort to technology providers operating in the UAE and aligns with a more pragmatic interpretation of the Central Bank Law. For the full FAQs, please see: lnkd.in/dxFfYxCs

Bottom Line: Yes - the U.S. is moving toward greater clarity and a more workable framework. But no - this is not a universal “green light” or a settled classification of the market.

Tokenized stocks, bonds, etc. = still securities (Jan 2026 SEC statement) Tokenization doesn’t change the legal nature of the underlying asset. Similar to UAE See TLP’s piece: mondaq.com/fin-tech/16727…

There’s a lot of noise around “the US just declared most crypto NOT securities.” That’s… not quite right. What is happening: a gradual shift toward clearer crypto market structure 👇

@SweCryptoLawyer @picaz_eth Why do you say that?

@picaz_eth this is still pretty bad

Important clarification from the Central Bank of the United Arab Emirates on the scope of Federal Decree-Law No. 6 of 2025. The distinction between regulating financial activity vs. regulating technology is now much clearer. #UAE #Fintech #Crypto #DeFi.

This includes: • Banking-as-a-Service platforms • Payment orchestration providers • Open banking API companies • Core banking system vendors Supporting licensed institutions does not, by itself, require a separate licence.

However and this is critical : If you are a technology provider serving licensed financial institutions, and you do not independently offer regulated financial services to end users, you are not automatically brought into scope.

Technology service providers can breathe easier. The Central Bank of the United Arab Emirates (CBUAE) has clarified one of the most debated provisions of Federal Decree-Law No. 6 of 2025. #crypto #payments #UAE #CBUAE #Dubai #Fintech #TLPAdvisors