🇧🇭 Bahrain vs 🇦🇪 United Arab Emirates (Dubai - VARA): crypto licensing compared

What changed recently

🇧🇭 Bahrain (verified 2026-07-15): In July 2025 the CBB issued a new Stablecoin Issuance and Offering (SIO) Module, added to Rulebook Volume 6, creating Bahrain's first dedicated stablecoin licensing framework. It covers issuance, minting, burning, and reserve management of single-currency stablecoins backed by BHD, USD, or other CBB-accepted fiat currencies; requires issuers to incorporate as a Bahraini B.S.C.; mandates perpetual redemption rights for holders; and explicitly permits yield-bearing stablecoins (subject to CBB-set limits). On 3 June 2026 AX Coin Bahrain B.S.C. (c), a subsidiary of Nasdaq-listed Solowin Holdings, announced it had been granted the first licence under this framework, for stablecoin issuer activities (per the issuer's announcement; a CBB press release confirming the grant is pending direct confirmation). Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025. In May 2026 the CBB restructured the approved-persons section (CRA-1.7) of the Crypto-Asset Module, regrouping its fit-and-proper, prior-approval and notification rules under relocated headings (Rulebook revision of 6 May 2026).

🇦🇪 United Arab Emirates (Dubai - VARA) (verified 2026-08-15): 'Rulebook 2.0' reissued all twelve rulebooks effective 19 Jun 2025 (mandatory Travel Rule, wind-down plans, TLPT, a new VA Issuance rulebook). VARA issued a circular implementing UAE federal anti-money laundering, counter-terrorism financing and proliferation financing requirements for VASPs (4 March 2026), an updated Travel Rule circular (24 February 2026), and an AML/CFT Business Risk Assessment Guidance (12 June 2026). VARA's rulebook site separately hosts a non-binding Guidance on the Virtual Asset Issuance Rulebook, covering two issuance pathways (Category 1: fiat- and asset-referenced tokens needing a VARA licence and reserve assets, except direct-ownership tokens; Category 2: other tokens, distributed only via VARA-licensed distributors or broker-dealers); this document carries no visible date on VARA's own rulebook page, but contemporaneous legal reporting consistently dates its publication to 9 April 2026. VARA has previously stated it penalised around 19 unlicensed firms. Legal-press reporting records VARA's 50th VASP licence (Tribe Tokenisation FZE) in early July 2026. No VARA news items have been published since 12 June 2026 as of 15 July 2026. VARA's own public register listed 52 licensed VASPs as of 1 August 2026, the most recent being Flipster FZE (exchange services, 14 July 2026); the register dates Tribe Tokenisation FZE, earlier reported by legal press as the 50th licensee, to 22 June 2026. No new VARA circular has been published since the 12 June 2026 AML/CFT Business Risk Assessment Guidance.