If you hand money to an exchange house, an app or a digital wallet in the UAE, three questions matter: who authorised them, what are they obliged to do with your money, and what happens if they fail. The answers are public, they changed recently, and they are not what most people assume.
The framework changed in June 2025
The Central Bank of the UAE's Exchange Business Regulation, C 7/2025, took effect on 26 June 2025. It is the current framework for exchange business, and legal commentary describes it as replacing the 2014 Regulations Regarding Licensing and Monitoring of Exchange Business. We could not locate an express repeal article naming the 2014 regulation, and some 2014-era standards remain on the Central Bank's rulebook, so "replaced" is the commentators' characterisation rather than a phrase we can point to in the instrument itself.
That matters for a practical reason: a great deal of published guidance about UAE exchange houses — including material written by people who know the market well — still treats the 2014 rules as the governing framework, without reference to what took effect in June 2025.
C 7/2025 licenses four activities:
- Currency exchange — buying and selling foreign currency
- Remittances — defined as "accepting money from a Payer for the purpose of money transmission or receiving money on behalf of a Payee"
- Salary processing through the Wage Protection System
- Pre-approved special products
The regulation also sets four licence categories, and the fourth matters here, because it is the one a digital-only provider needs: Category IV covers remittances via digital channels with no physical outlets. Wise holds exactly that authorisation and has still not launched an outbound service from the UAE, which is the cleanest illustration available of the gap between being licensed and being live.
The third one is worth pausing on. Salary processing through the WPS is a licensed exchange-business activity, which is why the Ministry of Human Resources lists Al Ansari Exchange and Lulu Exchange under "Partner Financial Institutions" for the WPS, alongside other named providers. For a large number of UAE expats, the same category of institution handles the salary arriving and the transfer leaving.
What the regulation makes them do with your money
The safeguarding requirement is the substantive protection, and the wording is specific. Customer funds:
"must deposit the funds received from its Remittance customers directly into one or more designated remittance intermediate account(s), opened with Bank(s) licensed by the Central Bank, on a daily basis or, at the latest, before the end of banking hours on the next business day following the day on which the funds were received."
And they must use those funds:
"solely for the purpose of settling the customers' Remittances with the foreign correspondents (i.e., correspondent banks, exchange houses, financial institutions or IMTS providers) and not for any other purposes."
Three things are being required there. The money goes into a designated account, not a general operating account. That account is at a bank the Central Bank licenses. And it happens on a daily cycle — by the end of the next business day at the very latest, so the window in which your money sits unsegregated is short by design.
The second clause is the one that matters in a failure. Ring-fenced money used solely for settling remittances is not available to the firm's general creditors in the way its own working capital would be.
Wallets are governed separately
If the product holds a balance for you rather than simply moving money, it is likely a stored value facility, governed by the Stored Value Facilities Regulation, C 6/2020, effective 30 October 2020 and still in force.
Article 11 requires the licensee to have "an effective contractual arrangement to ensure the legal right and priority claim of the Float by Customers in the event of insolvency of a Licensee", with float assets held in segregated accounts at licensed banks. A bank guarantee or insurance is permitted as an alternative arrangement.
The mechanism is the same idea as the remittance rule, expressed for a held balance rather than money in transit: segregation, plus a contractual structure putting customers ahead of general creditors.
There is also a Retail Payment Services and Card Schemes Regulation, Circular No. 15/2021, issued in July 2021 and effective from 1 August 2022, which covers payment service providers more broadly.
What none of it does
Here is the part that surprises people, so here it is plainly.
Neither C 7/2025 nor C 6/2020 creates a deposit guarantee, deposit insurance or compensation scheme for customers.
Both regulations do contain guarantee machinery, and it is worth being precise about who it protects. The Exchange Business Regulation requires a minimum bank guarantee — running from AED 2 million to AED 50 million depending on the licence category and legal form, but that guarantee is given in favour of the Central Bank, not to individual customers. The Stored Value Facilities Regulation permits a bank guarantee or insurance cover as an alternative way of protecting the float. Neither is a customer compensation scheme.
What you have as a customer is segregation and a priority claim in insolvency. There is no state backstop, no guaranteed payout figure and no equivalent of the compensation schemes that exist in some other jurisdictions for bank deposits. If a licensed exchange house failed, the segregated money should be there and should be yours ahead of general creditors, but that is a mechanism working correctly, not a promise that a number will be paid regardless.
The one-line version worth remembering: money at an exchange house is segregated, not guaranteed.
For money in transit over a day or two, this is largely academic. It becomes relevant if you are treating a wallet or an exchange house balance as somewhere to park funds, which is a different activity from moving them.
A licence is not a launch
One more distinction that has caused real confusion in this market.
Wise obtained Central Bank licences in October 2025 and it was widely reported. Nearly eleven months later, Wise's own UAE page still states: "We're working hard to allow customers to send from the United Arab Emirates - but we're not quite there yet."
A licence is permission to operate. It is not evidence that a service exists, and the gap between the two can be long. When a licence announcement appears, the thing to check is the provider's own product page, not the coverage.
The question to ask about any app
A growing share of consumer money-movement products in the UAE are interfaces over someone else's licence. That is normal and the framework contemplates it.
Careem is a clear example, and it is candid about it. Careem's own site states that "Careem Pay provides international money transfers in partnership with Lulu Exchange" and describes the service as authorised and regulated by the Central Bank, with LuLu named as the licensed entity. Careem does not claim a remittance licence of its own.
So the useful question for any app is: which licensed entity am I actually contracting with? The answer is usually in the help centre rather than the marketing, and it changes how you should read a comparison. Two products on the same underlying licence are two pricing layers, not two institutions.
How to check a provider yourself
None of this requires specialist knowledge.
- Find the licensed entity. Look in the site footer and the help centre, not the homepage. Al Ansari's Key Facts Statement names "Al Ansari Exchange LLC"; LuLu's footer names "LuLu International Exchange".
- Check whether the app is the licence holder or a partner. If the wording is "in partnership with", the partner is who you are relying on.
- Work out which regulation applies. Moving money is C 7/2025. Holding a balance for you is C 6/2020.
- Do not assume a compensation scheme. There is not one for either.
- Treat a licence announcement as permission, not availability. Check the product page.
EW+ View
Regulation in this market does a specific and fairly narrow job, and it does it reasonably well. Customer money must be ring-fenced quickly, at a licensed bank, and used only for its purpose. Wallet float carries a contractual priority claim. Both requirements are public and specific enough to check.
What regulation does not do is make providers disclose what they charge. C 7/2025 licenses the activity; it does not require anyone to publish an exchange rate margin, and not one provider in this market does. So the regulatory framework tells you your money is unlikely to disappear, and tells you nothing about whether you are getting a fair price. Those are separate questions and it is worth keeping them separate.
The most common error we see is the reverse of overconfidence — people assuming an exchange house is unregulated when it is licensed under a framework that was tightened last year. The correction runs both ways: it is more regulated than most people think, and it protects less than the word "regulated" implies.
Common questions
The Exchange Business Regulation C 7/2025, effective 26 June 2025, which replaced the 2014 Regulations Regarding Licensing and Monitoring of Exchange Business. Guidance still citing the 2014 rules as current is out of date.
Under C 7/2025, customer funds must be deposited into designated remittance intermediate accounts at Central Bank–licensed banks on a daily basis, or at the latest before the end of banking hours on the next business day, and held solely for settling customers' remittances with foreign correspondents and for no other purpose.
No. Neither C 7/2025 nor the Stored Value Facilities Regulation C 6/2020 creates a deposit guarantee, insurance scheme or compensation fund. What you have is segregation of your money and a priority claim in an insolvency. Segregated is not the same as guaranteed.
The Stored Value Facilities Regulation C 6/2020, effective 30 October 2020. Article 11 requires an effective contractual arrangement establishing customers' legal right and priority claim over the float in an insolvency, with float assets in segregated accounts at licensed banks. A bank guarantee or insurance is a permitted alternative.
No. Wise obtained Central Bank licences in October 2025, and nearly eleven months later its own UAE page still says it cannot yet let customers send from the United Arab Emirates. A licence is permission to operate; check the provider's own product page for whether a service actually exists.
Look at the footer and the help centre rather than the marketing. If the wording is "in partnership with" a named exchange house, that partner is the licensed entity and is who you are relying on. Careem, for example, states that Careem Pay provides international transfers in partnership with LuLu Exchange.
No. C 7/2025 licenses the activity and sets safeguarding obligations; it imposes no requirement to disclose a margin. No provider in this market publishes one, which is why fee comparisons between them are of limited use.
Next steps
- Find the licensed entity behind any provider you use — footer and help centre, not the homepage.
- If an app describes itself as operating "in partnership with" someone, note who the partner is.
- Do not park a balance anywhere on the assumption that a compensation scheme exists. There is not one.
- Treat any licence announcement as permission to operate, and check the product page for availability.
- Remember that regulation here covers safety of funds, not fairness of pricing — those are separate questions.
Further reading on ExpatWealthPlus
- A bank wire or an exchange house
- Al Ansari and LuLu: what each actually publishes
- Careem Pay and LuLu Exchange
- Why you cannot send money out of the UAE with Wise
- What DFSA regulation means
Official sources
Every figure in this article is checked against the primary source. These are the places to verify the current position for yourself, since rates, rules and product terms change.
- CBUAE — Exchange Business Regulation C 7/2025 →Effective 26 June 2025; the four licensed activities and the safeguarding rule
- CBUAE — Stored Value Facilities Regulation C 6/2020 →Article 11, the priority claim over float on insolvency
- CBUAE — Retail Payment Services and Card Schemes Regulation 15/2021 →Issued July 2021, effective 1 August 2022
- MoHRE — Wage Protection System →The approved banks, financial institutions and exchange houses
- Careem help centre — is Careem licensed for this service →An example of an app naming its licensed partner
- Wise — send money from the UAE →A licence obtained in October 2025 with the service still not launched