Setting up in the UAE: Assessment Questions for Fintechs

Assessment Questions to Understand the Fintech’s Business Model and Needs



We recently consulted for a Fintech from an European market that was planning to setup operations here in the UAE. These were the questions we asked to guide them in their setup decision. 

1. Business Model and Services

• What specific payment services do you plan to offer in the UAE? (e.g., payment account issuance, payment instrument issuance, merchant acquiring, payment aggregation, domestic/cross-border fund transfers, payment token services, or payment initiation/account information services)
• Will your services involve issuing stored value (e.g., digital wallets) or handling high transaction volumes (≥ AED 10M monthly)?
• Are you targeting B2B, B2C, or both? Who are your primary customers (e.g., merchants, individuals, other fintechs)?
• Will you operate solely within the UAE or also serve international markets? If international, which regions are prioritized?
• Do you have existing technology or platforms, or will you develop new infrastructure in the UAE?

2. Financial and Operational Capacity

• What is your estimated initial capital budget for setting up in the UAE, and what are your funding sources?
• What is your projected monthly transaction volume for the first 1-2 years?
• How many employees do you plan to hire locally, and what is the planned number of visa sponsorship for expatriate staff?
• Do you have existing AML/CFT, IT security, or risk management frameworks, or will these need to be developed?
• Are you planning to lease physical office space, or do you prefer flexible options like serviced offices?

3. Ownership and Governance

• Who are the shareholders, and what is the ownership structure (e.g., individual, corporate, mixed)?
• Are you seeking 100% foreign ownership, or are you open to local sponsorship if required?
• Do you have a preference for a specific legal entity type (e.g., LLC, Private Company etc.)?
• What is your governance structure, including board composition and key management roles?

4. Regulatory and Compliance Experience

• Presumably, you operate as a PSP or similar regulated entity in other jurisdictions? If so, under which other regulators?
• Presumably, you are compliant with AML/CFT requirements or PCI DSS standards as relevant?
• Do you have experience with technology risk management or cybersecurity compliance (e.g., penetration testing, Information Assurance Standards)?
• Are you prepared for ongoing reporting obligations, such as quarterly transaction reports or annual audits?

5. Strategic Goals and Preferences

• Why did you choose the UAE for your PSP setup (e.g., market access, tax benefits, fintech ecosystem)?
• Do you have a preference for mainland UAE,  or financial freezones, or are you open to recommendations based on cost, regulation, or market access?
• Are you interested in innovation programs, such as DIFC’s Innovation Testing License or ADGM’s fintech sandbox?
• What is your timeline for obtaining a license and commencing operations?
• Are you planning to collaborate with local banks, fintechs, or other partners in the UAE? What will be your go to market in this regard?

The answers to these questions will help shape up a Fintech's decision to setup shop here.

There are three jurisdictions to choose between: 1) Mainland UAE (regulated by UAE Central Bank) 2) DIFC (regulated by the DFSA)  3) ADGM (regulated by the FSRA).

We will cover the key differences in these jurisdictions in later post.