The Regulations on the Marketing of Virtual Assets and Related Activities 2024 are among the most consequential regulatory developments in UAE crypto law. The Marketing Regulations apply to every entity that markets virtual assets to UAE residents, regardless of whether the entity is itself licensed in the UAE. The territorial reach is deliberate and has caught many international crypto businesses by surprise.
Non-compliance with the Marketing Regulations carries meaningful penalties and creates regulatory exposure that complicates future licensing applications. This guide sets out what the regulations require, who they apply to, and how to design a compliant marketing approach for UAE-targeted activity.

The Marketing Regulations apply to all entities, including domestic and foreign entities, and whether or not they are authorised and licensed by VARA to carry out virtual asset activities. The trigger is the marketing activity itself, directed at UAE residents, regardless of where the entity is based.
This is a critical point that many offshore crypto businesses still miss. An exchange based in Hong Kong, a token project based in Switzerland, a marketing influencer based in Pakistan, and an OTC desk based in Singapore are all subject to the Marketing Regulations if they market virtual assets to UAE residents. The penalties for non-compliance apply to the entity even if it has no physical presence in the UAE.

The definition of marketing under the Regulations is intentionally broad. It covers advertising in traditional media, online advertising, social media promotion, influencer marketing, content marketing including educational articles and videos, sponsored events, direct outreach including email and messaging campaigns, and broader brand-building activity oriented at UAE audiences.
What matters is the intent and the targeting, not just the channel. A YouTube video produced abroad but with content specifically directed at UAE viewers is marketing. A Telegram channel administrated abroad but actively promoting trades to UAE-based subscribers is marketing. A Twitter thread amplified through paid promotion targeting UAE audiences is marketing. The regulator looks at the practical reach and the apparent intent.

Marketing must be fair, clear, and not misleading. Specific representations about returns, risk levels, or capabilities must be substantiated. Misleading or unsubstantiated claims are a primary enforcement focus.
Marketing must include appropriate risk warnings. The Regulations specify the form and content of risk warnings that must accompany marketing of virtual assets. Generic disclaimers buried in fine print do not satisfy the requirements.
Marketing must not target retail investors with products unsuitable for them. The Regulations apply different standards to marketing aimed at retail audiences versus marketing aimed at professional or institutional audiences. Products that can only be offered to professional investors cannot be marketed to retail audiences.
Marketing of unlicensed virtual asset services to UAE residents is prohibited. A foreign exchange that is not licensed by VARA, the DFSA, or FSRA cannot market its exchange services to UAE residents. The prohibition is absolute and is one of the most actively enforced provisions.
Influencer marketing is subject to specific transparency requirements. Influencers must clearly disclose paid relationships, must not present themselves as financial advisors unless qualified to do so, and are personally exposed to the consequences of breach. Several influencer enforcement cases have been pursued through 2024 and 2025.

VARA has issued enforcement notices to entities marketing virtual assets in or to Dubai without authorisation. Between August 2024 and August 2025, VARA issued enforcement notices against 36 firms for violations including unlicensed virtual asset activities and unauthorised advertising.
The enforcement options available to VARA include public warnings, financial penalties, prohibition orders that prevent further marketing activity, referral for criminal prosecution under federal cybercrime legislation, and notification to the entity’s home regulator (where applicable). For foreign entities, the regulatory exposure extends to their home licence and to their banking relationships globally.
Influencer enforcement has been particularly visible. Several social media influencers based in or active in the UAE have faced public enforcement actions for promoting unlicensed products or making misleading claims about virtual asset returns.

Compliant marketing of virtual assets to UAE residents starts with the licensing question. If the underlying service is not licensed in the UAE, marketing it to UAE residents will generally not be compliant regardless of how the marketing is structured.
Where the underlying service is licensed, compliant marketing requires substantive review of the marketing materials, the targeting parameters, the risk warnings, and the influencer relationships. The Regulations and the accompanying Guidance set out the specific requirements in detail and benefit from specialist review at the design stage rather than after publication.
Educational content has more flexibility than promotional content but is not unregulated. Content that explains crypto concepts in a neutral and balanced way faces lower compliance burdens than content that promotes specific products or services. The line between education and marketing is sometimes contested and benefits from legal review where the content might be ambiguous.

Foreign crypto businesses operating UAE-targeted marketing programs face a coordination challenge. The marketing must satisfy the requirements of the home jurisdiction, the targeted jurisdiction (the UAE), and any third-party platforms involved (such as advertising networks, social media platforms, and influencer agencies).
Most major advertising networks now have UAE-specific policies that reflect the Marketing Regulations. Social media platforms have implemented restrictions on crypto advertising that vary by jurisdiction. Compliance is rarely a single-jurisdiction question, and coordination across the relevant frameworks is part of any properly designed marketing program.