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This month, the US Securities and Exchange Commission (SEC) proposed Regulation Crypto Assets, its first tailored securities offering regime for crypto investment contracts. It’s a significant step, and one that deserves credit. But it also reveals something the UAE has understood for years: bespoke regulation, not blanket caution, is what turns speculative capital into durable infrastructure.
The SEC’s proposal creates two exemptions: a startup exemption capped at $5 million over four years, and a fundraising exemption, allowing up to $75 million per year, alongside a conditional safe harbour letting issuers exit investment-contract status once their managerial obligations are complete. It is a serious first attempt at giving digital asset issuers a workable on-ramp to build infrastructure and operate.
While the SEC’s proposed Regulation Crypto Assets relies on exemptions to bridge the gap with legacy laws, the UAE’s VARA VA Issuance Rulebook and ADGM’s Digital Asset Framework have already established dedicated, technology-neutral pathways. These rules don’t offer ‘exemptions’ from a legacy regime; they provide a primary, purpose-built framework that allows issuers to scale from day one with total legal certainty.
This is an opinion article written and shared by industry experts with their independent views about the topic. ONE.io builds cross-border payments infrastructure spanning fiat, stablecoins and FX, the exact category of business this piece argues UAE regulation uniquely enables.
So why is everyone else still playing catch-up to the UAE?
Europe, meanwhile, offers a lesson in what happens when comprehensive regulation doesn’t translate into usable infrastructure. MiCA reached full implementation in July 2026, and yet after its stablecoin provisions took effect, regulators across the EU had authorised a few dozen e-money token issuers. That is not a failure of ambition, but it is a signal that thoroughness without pace can leave a market under-served exactly when demand is accelerating elsewhere.
Set against both of these approaches is a jurisdiction that has quietly been doing this work since 2023. The UAE’s Virtual Assets Regulatory Authority and Abu Dhabi Global Market have spent the past three years iterating, not deliberating, building out issuance rulebooks for stablecoins and real-world assets, formal derivatives frameworks, and even standardised marketing rules. The result shows up in the numbers: the country attracted an estimated $34 billion in crypto inflows, and now ranks among the highest per-capita crypto adopters in the world.
Does regulatory maturity matter more than adoption rates?
What often gets missed in headline figure adoption comparisons is that regulatory maturity isn’t just about legitimising trading; it’s about what businesses can actually build once the rules are set. This is where the UAE’s advantage compounds.
I’ve spent my career watching businesses in iGaming, Web3, commodities, and cross-border trade get treated as too complex for fintechs and too exotic for high street banks. They end up stitching together a fiat rail here, a crypto wallet there, an FX provider somewhere else, and running treasury on fragmented infrastructure that cannot keep pace with how they actually operate. That fragmentation is specifically a regulatory problem. Providers won’t build unified, compliant rails for sectors where the rules are still being written, or worse, are unevenly enforced. They build where the rules are settled.
That is precisely the environment the UAE has created. With VARA and ADGM’s frameworks now mature, providers serving cross-border, high-growth businesses can build genuinely joined-up infrastructure spanning fiat, stablecoins, and FX, without waiting for regulatory certainty that other markets are only now beginning to establish. It’s no coincidence that institutional capital has followed.
Catching Up Takes Time
None of this means the US and EU won’t catch up. The SEC’s proposal is a genuine step toward the kind of tailored framework the UAE built years ago, and Europe’s banking consortiums are already trying to solve MiCA’s slow-authorisation problem with their own euro stablecoin initiatives. But catching up takes time, and in a market where capital moves as fast as this one does, a multi-year head start is not a minor advantage. It is close to decisive.
For businesses building genuinely global, always-on financial infrastructure, the message from the last two months of regulatory activity is clear. The US is starting to ask the right questions. Europe has the right instincts but the wrong pace. The UAE has already answered both, and is now reaping the benefits of getting there first.