Middle East/DIFC/Comparables
DIFC
DFSA
The characterisation jurisdiction of the three UAE files. DFSA splits Investment Tokens from Crypto Tokens. Get that wrong and the rest of the rulebook is the wrong book. No passport into mainland Dubai or ADGM.
Seat
DIFC
Split
2-way
Passport
None
Similar regulation
The statute book
Primary instruments, with the RCA job each one actually does. Links open the official text.
- DFSA Investment Token and Crypto Token regimeDIFC financial-services rules for tokenised instrumentsIn force
The Rule 100 filter (2) conversation — is the token itself a security?
Translation
Rule 100–500 map
| RCA | Peer | Fit | Desk |
|---|---|---|---|
| Rule 100 filter (2) | Investment Token vs Crypto Token | Analogue | If it is an Investment Token, it is not a RCA crypto asset. |
| Rule 300 | DFSA offering / financial-services permission for the relevant token class | Partial | Centre permission, not a US exemption. |
| Rule 400 | None | No analogue | An Investment Token does not cease by filing a TR. |
Analysis
What the file is
DIFC is where the UAE file most closely tracks Rule 100’s second filter. An Investment Token is treated as a financial instrument. A Crypto Token is not, and is pulled into a lighter, still-authorised Crypto Token regime. A tokenised share issued in the Centre is an Investment Token and is therefore, in RCA terms, not a subject crypto asset. Counsel who want a Gulf CIC will not find it here; they will find a characterisation memo.
Research
The record
- DFSA rule-making history (2022 Crypto Token regime, subsequent iterations) is public. Use the current module, not a launch deck.
- No passport: a DFSA-authorised firm is not thereby VARA-licensed or FSRA-authorised.
Ideation
What to file
- Use DIFC as the exhibit for “filter (2) is doing real work.” If your token would be an Investment Token in the Centre, it is probably a digital security in the US, and Rule 100 does not attach.
Analysis
What the file is
DIFC is where the UAE file most closely tracks Rule 100’s second filter. An Investment Token is treated as a financial instrument. A Crypto Token is not, and is pulled into a lighter, still-authorised Crypto Token regime. A tokenised share issued in the Centre is an Investment Token and is therefore, in RCA terms, not a subject crypto asset. Counsel who want a Gulf CIC will not find it here; they will find a characterisation memo.
Related RCA sections
Primary sources on file
DFSA — Investment Tokens and Crypto Token regime (DIFC)
Dubai Financial Services Authority/1 Nov 2022/RCA review 15 Jul 2026
Primary regulatory
RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.