NEWS & INSIGHTS

Not too long ago, the Central Bank of Jordan (“CBJ”) was issuing warnings against the use of cryptocurrencies within Jordan[1]. Today, Jordan has taken a revolutionary step towards regulating virtual assets and their use in Jordan by means of issuing the Virtual Assets Transactions Regulation Law for the year (2025) (“Virtual Assets Law”)[2], which became effective on September 14^th, 2025. While Jordan may be later than some countries within the MENA in establishing such legislation, it remains one of the first players within the region in this area, particularly given that multiple other countries, including Kuwait[3], Egypt[4], and Iraq[5], are still prohibiting the use of virtual assets. Jordan’s issuance of the Virtual Assets Law now prompts a significant question: does it align with regional laws and specifically UAE laws, or does it pave a unique path tailored to the country’s own domestic context?

            With UAE emerging as the region’s digital finance capital, hosting more than 500,000 daily crypto traders[6], it has adopted a vigorous multi layered legal framework. On the federal level, the UAE Securities and Commodities Authority is designated as the regulatory authority to grant licenses to any person (whether natural or not natural) within the UAE -excluding financial free zones- to engage in virtual assets activities[7], namely:

the “provision of Virtual Asset Platform operation and management services, the provision of exchange services between one or more forms of virtual assets, the provision of Virtual Asset transfer services, the provision of brokerage services in trading operations in Virtual Assets, the provision of Virtual Asset custody, management, and control services, and the provision of financial services related to offering and/or selling by the issuer of the Virtual Assets or participating in providing those services”[8].

On the emirate level, the Dubai Virtual Assets Regulatory (“VARA”), the world’s first independent regulator for virtual assets[9], is in charge of regulating, supervising, and overseeing virtual assets services[10]. This, in effect, means that no person may conduct virtual asset activities in Dubai, without obtaining a license from VARA[11]. As for DIFC, a financial free zone in Dubai[12], and ADGM – the financial-free zone located in the center of Abu Dhabi-[13], both have their own regulatory bodies which are the Dubai Financial Services Authority and Financial Services Regulatory Authority respectively[14].

When it comes to virtual assets being designated for payment purposes, this activity falls under the competence of the Central Bank of the United Arab Emirates, which is planning to launch its own central bank digital currency, the “Digital Dirham”[15], in the fourth quarter of this year[16] for that specific purpose. Unlike cryptocurrencies, which are decentralized, volatile, and inherently risky, the Digital Dirham will be state-backed, stable, and secure. While it does not directly compete with cryptocurrencies, it is intended to provide the UAE with a reliable digital means of payment, moving the country toward a cashless society and better equipping it to operate and thrive in the anticipated tokenized global economy[17].

The above captioned multi-faceted legislative approach is well-suited to UAE’s federal structure and is particularly relevant given its role as a hub for financial services.

In the UAE, 27.67% of the UAE’s total population owns virtual assets[18], positioning the country as one of the global leaders in crypto adoption. This is achieved by fostering an environment favorable to individual participation in the digital asset market, whether through incentives and exemptions or regulatory clarity. For example, financial services in the UAE, including the transfer of ownership of virtual assets as well as cryptocurrencies, the exchange of virtual assets, and managing and safeguarding of virtual assets and enabling control thereof, are all exempt from Value Added Tax retroactively as of January 1^st, 2018, unless such services are provided in lieu of explicit fee, discount, commission, or rebate or similar[19].

Conversely, Jordan has issued the Virtual Assets Law under the authority of the Jordan Securities Commission (“JSC”)[20], which has the power to grant licenses to non-natural persons to engage in or promote virtual asset activities for the benefit of others. Unlike the UAE[21], such licenses cannot be granted to natural persons and may only be issued to non-natural persons who meet the conditions set forth in the forthcoming regulations, which have not yet been issued[22]. Such legislative stance reflects Jordan’s more tailored approach, with the JSC as the primary licensing authority for virtual asset activities, while the Central Bank of Jordan retains general competence over the use of virtual assets for payment purposes—permitted only according to requirements intended to be outlined through future instructions that have not yet been issued[23].

Further to the above, we note that Jordan has identified virtual asset activities in line with UAE legislation, namely Jordan’s Virtual Assets Law has designated the following activities as virtual asset activities if undertaken for the benefit of others:

• operating and managing virtual asset platforms;
• exchanging virtual assets for Jordanian or foreign currency;
• exchanging one or more forms of virtual assets;
• transferring virtual assets from one address or account to another;
• safekeeping and managing virtual assets or any tools that enable control over them;
• providing brokerage services for trading in virtual assets; and
• participating in or providing financial services related to the offer or sale of virtual assets by an issuer[24].

To that end, Jordan permits natural persons to engage in such activities only for their own benefit, but prohibits them from the activity of promoting such virtual assets[25]. However, Jordan has not introduced any tax exemptions or benefits for such individuals, unlike the provisions offered under UAE law.

The legal frameworks of both the UAE and Jordan reflect a clear alignment in their approach to transparency obligations for virtual asset service providers (“VASPs”), particularly around compliance with international financial integrity standards. Both jurisdictions require VASPs to adhere to Anti-Money Laundering, Counter-Terrorist Financing, and Counter-Proliferation of Weapons of Mass Destruction laws and regulations[26], as well as to obtain all data related to the parties to a transfer and any intermediaries, in line with applicable legislation[27].

Jordan’s newly enacted Virtual Assets Law, however, remains at a relatively early stage. Its transparency requirements are broad and principle-based, primarily centered on AML/CFT compliance and data collection, with a bold provision that VASP bank accounts shall not enjoy banking secrecy in respect of any inquiry submitted by the Chairman of the JSC[28]. It is anticipated that the JSC will issue further instructions and guidelines to provide greater clarity and operational detail. The UAE framework, by contrast, builds on the same foundation but is more developed and regulated. In addition to AML/CFT compliance, VASPs must implement in Jordan technical and operational transparency measures, including the obligation to disclose to investors all service-related risks to investors in a clear, fair, and non-misleading manner[29], to notify the Securities and Commodities Authority and relevant authorities of any security risks, breaches, or conduct amounting to cybercrime[30], and to support enhanced information sharing whereby local authorities such as VARA shall provide the Securities and Commodities Authority with all required information on VASPs[31].

Accordingly, while Jordan and the UAE are aligned in direction and underlying principles, the UAE regime represents a more mature and informed implementation, whereas Jordan’s framework is expected to evolve through secondary regulations and regulatory practice.

In conclusion, Jordan’s Virtual Assets Law is carefully tailored to its domestic context. While the new law aligns with regional regulatory practices, it seems prima facie that its primary aim would be the regulation of an existing market rather than the positioning of Jordan as a financial regional hub in virtual assets. Such legislative position reflects Jordan’s cautious yet progressive stance in embracing digital finance. The UAE, by contrast, particularly through the issuance of the Digital Dirham is taking a far more ambitious strategy. Rather than merely adapting to an emerging market, it aims to establishing itself globally as a dominant player of digital assets, preparing itself for a tokenized economy and potentially centralizing digital means of payment reclaiming sovereignty and control over the creation of virtual money.