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Payment Services

Payment Services & E-Money Licensing — CBUAE, DFSA & Mauritius

A payment licence without the right structure, AML/CFT programme, and banking relationship is an incomplete solution. We manage the full UAE payment licensing process — from the right regulatory framework to the first transaction.

Free Licensing Assessment Licensing Services
CBUAE SVFDFSA Payment ServicesPSP LicensingE-MoneyRemittanceAML/CFT
350+
Companies Structured
6
Jurisdictions
CBUAE
SVF & PSP Expertise
4 Mo
Avg. SVF Timeline
Sound Familiar?

What Payment Businesses Are Navigating in the UAE

Payment licensing in the UAE is more complex than it appears. These are the questions every payment business faces before — and after — submitting to the regulator.

"Which licence do we need — SVF, PSP, or money remittance?"
The CBUAE has distinct licence categories: Stored Value Facility (Class A, B, or C), Payment Token Service Provider, Retail Payment System Operator, and money remittance. The right licence depends on your product, customer base, transaction volumes, and whether funds are stored. Choosing the wrong one means reapplying.
"What are the capital requirements — and do we actually have to hold that?"
CBUAE SVF Class A requires AED 50 million paid-up capital. Class B requires AED 2 million. Beyond capital, client funds must be safeguarded in segregated accounts at a licensed UAE bank. Many applicants underestimate the safeguarding requirement and the time it takes to open the relevant banking relationships before submission.
"We need a bank account to operate — but banks won't open one for a payment business without a licence."
This is the most common operational paradox in UAE payment licensing. CBUAE requires evidence of a banking relationship in the application, yet banks routinely decline payment businesses without a licence. We have established relationships with UAE banks that work with payment licence applicants and manage this process in parallel with the CBUAE application.
"What AML/CFT programme does a CBUAE-licensed payment business need?"
CBUAE-licensed payment businesses are subject to UAE AML/CFT law and CBUAE AML supervision standards. The application must include a complete AML/CFT policy manual, a designated MLRO, a customer due diligence framework, transaction monitoring procedures, and a risk assessment. The CBUAE scrutinises AML/CFT submissions carefully — a weak programme is a common reason for delays or rejection.
"We want to be in DIFC but also serve clients across the UAE. Is that possible?"
DIFC is a separate regulatory jurisdiction within the UAE, regulated by the DFSA. A DFSA Payment Services permission covers operations within DIFC. Actively servicing mainland UAE customers may require a parallel CBUAE arrangement. The right structure depends on your customer geography, distribution model, and whether you intend to maintain a physical presence outside DIFC.
"How long will this actually take — and what can we do in the meantime?"
A CBUAE SVF Class B application takes 4–8 months from a complete submission. The timeline is determined by the quality of the application, not just the regulator's calendar. An incomplete or poorly structured submission adds months. We prepare applications that are complete on first submission and manage all CBUAE interactions from that point forward.
Regulatory Frameworks

Payment Licensing Options — UAE & Mauritius

The right framework depends on your product, customer geography, and capital position. Most UAE payment businesses choose one primary regulator and structure secondary activity around it.

CBUAE — Mainland UAE
Stored Value Facility (SVF) — Class A
Open-loop, general-purpose e-money for the public. AED 50M capital. Full AML/CFT programme, CBUAE supervision. For large-scale digital wallets and payment platforms.
CBUAE — Mainland UAE
Stored Value Facility (SVF) — Class B
Open-loop, limited scope e-money. AED 2M capital. Most common licence for fintech startups launching consumer or B2B payment products in the UAE.
CBUAE — Mainland UAE
Money Remittance Licence
Cross-border money transfer services. Requires a CBUAE remittance licence, AML/CFT programme, and correspondent banking relationships. Specific requirements for unbanked customer segments.
CBUAE — Mainland UAE
Payment Token Service Provider
For businesses issuing, converting, or facilitating payment tokens (including stablecoins used for payment). Subject to CBUAE Payment Token Services Regulations (2023).
DFSA — DIFC
Providing Payment Services
DFSA financial services permission for payment services within DIFC. English common law framework, strong international credibility. Often used alongside a CBUAE licence for international payment businesses.
FSC — Mauritius
Payment Intermediary Scheme (PIS)
For cross-border payment and fintech businesses using Mauritius as a holding or operational base. Extensive double-tax treaty network, lower cost structure, FSC oversight.
A GCC-based fintech approached us with a consumer digital wallet product and no regulatory footprint. They had been declined by two banks before engaging us. We identified the CBUAE SVF Class B as the right licence, structured the company correctly, built the AML/CFT programme from scratch, and managed the banking introduction in parallel with the CBUAE submission. The licence was granted in four months. The banking relationship was in place before approval.
4
Months to Licence
SVF
Class B — CBUAE
Day 1
Banking Ready
What We Delivered

Licence, AML/CFT & Banking — in One Engagement

A payment licensing engagement with us covers everything the CBUAE (or DFSA) requires — and everything needed to actually operate once the licence is granted. We do not hand over a licence without making sure the business can use it.

  • Licence class selection and regulatory structuring
  • Company setup in the right jurisdiction and free zone
  • Full CBUAE or DFSA application — business plan, financial projections, AML/CFT
  • AML/CFT policy manual and MLRO appointment
  • Banking introduction and safeguarding account setup
  • CBUAE or DFSA liaison throughout review
  • Post-licence compliance programme and ongoing support
Free Licensing Assessment
Our Payment Services Advisory

End-to-End Payment Licensing Support

Licence Selection & Structuring
We assess your product, business model, customer geography, and capital position to identify the correct licence class and regulatory framework. This includes the choice between CBUAE and DFSA, the right free zone or mainland structure, and whether a Mauritius PIS structure is appropriate as a holding or operational layer.
CBUAE SVF Application
Full preparation and submission of the CBUAE Stored Value Facility application — business plan, financial model, operational policies, IT security documentation, AML/CFT programme, and fitness and propriety submissions for key persons. We manage all CBUAE interactions from initial submission to licence issuance.
DFSA Payment Services Licence
For businesses requiring a DIFC-based payment services permission, we prepare and manage the DFSA application process. This includes regulatory business plan, financial projections, systems and controls documentation, and AML/CFT programme aligned to DFSA rules.
AML/CFT Programme Design
Payment businesses face specific AML/CFT risks — transaction layering, anonymous loading, cross-border flows, and unbanked customer segments. We design AML/CFT programmes that are proportionate, regulator-ready, and operationally functional — not just a document that passes the application stage.
Banking & Safeguarding Setup
We have working relationships with UAE banks that serve payment businesses. We introduce clients, support the account opening process, and ensure safeguarding accounts are in place before or concurrent with licence issuance. We also advise on correspondent banking for international payment flows.
Ongoing Compliance & Regulatory Maintenance
Post-licence, payment businesses face ongoing CBUAE or DFSA reporting obligations, annual AML/CFT risk assessments, and regulatory change. We provide retainer-based compliance support — outsourced MLRO, compliance monitoring, regulatory reporting, and licence condition management.
Common Questions

Payment Licensing FAQs

The CBUAE regulates mainland payment services — the primary licence is the Stored Value Facility (SVF), available in Class A (large-scale, AED 50M capital), Class B (mid-scale, AED 2M capital), and Class C (closed-loop/limited purpose, AED 500K). Additional CBUAE categories include Payment Token Service Providers, Retail Payment System Operators, and money remittance licences. The DFSA in DIFC offers Payment Services permissions for DIFC-based operations. Mauritius (FSC) offers the Payment Intermediary Scheme for cross-border payment businesses.
Capital requirements vary by SVF class: Class A requires AED 50 million paid-up capital; Class B requires AED 2 million; Class C requires AED 500,000. Beyond capital, all SVF licence holders must maintain client safeguarding — client funds must be held in segregated accounts at a CBUAE-licensed bank, separate from operating capital. The safeguarding requirement is enforced from the point of licence issuance and requires a banking relationship to already be in place.
Yes. CBUAE-licensed payment businesses are subject to UAE AML/CFT laws and CBUAE AML/CFT Supervision Standards. The application must include a full AML/CFT policy manual, a designated MLRO, customer due diligence procedures, transaction monitoring, suspicious transaction reporting procedures, and an AML/CFT risk assessment. The CBUAE reviews AML/CFT submissions in detail — a poorly designed programme is a common cause of delays or rejection. Post-licence, annual AML/CFT risk assessments and CBUAE compliance reviews are required.
DIFC is a separate regulatory jurisdiction within the UAE — a DFSA Payment Services permission covers activity within DIFC. Actively marketing to or servicing customers in mainland UAE may require a separate CBUAE licence or a formal nexus arrangement. The answer depends on how customers are acquired, where transactions are initiated, and whether the business has a physical presence outside DIFC. This is a common structuring question and we advise on the right architecture for each business model.
A CBUAE SVF Class B application typically takes 4–8 months from a complete, well-prepared submission. The single biggest variable is application quality — incomplete submissions, weak AML/CFT programmes, and unexplained gaps in key person documentation extend the timeline significantly. DFSA Payment Services applications typically take 4–6 months. We prepare applications that are complete on first submission, which is the most reliable way to manage timeline.
Interactive Scenario

Can you get the licence and keep the business?

Take the compliance seat at a payments start-up building for the Gulf and beyond. Eight decisions on regulatory perimeter, licence route, capital, safeguarding, agents, outsourcing and supervision. Every choice moves your timing, your capital and your standing with the regulator.

Play the game →
8
Decisions
3
Measures
10 min
To play
A payment licence without a banking relationship is an incomplete solution.
A free licensing assessment is where every payment engagement starts. We review your product, business model, and capital position — and tell you exactly which licence you need, what it takes to get it, and how long it will realistically take.
Free Licensing Assessment Licensing Services AML/CFT & Compliance