Practice

Financial Crime, Crypto & Asset Recovery

In the UAE, a cryptocurrency transaction can become a criminal matter within hours. We advise and defend businesses and individuals when digital assets become the subject of police investigations, AML allegations, or enforcement action — and we step in early, before the situation escalates.

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When we step in
1A crypto transaction (P2P or exchange) triggered a police check or account freeze
2A bank has requested proof of source of wealth (SOW) and restricted operations
3Your business or assets are under AML monitoring under Federal Decree No. 20 of 2018
4Legal support is needed for digital asset transactions under VARA or SCA rules
Overview

When a cryptocurrency matter becomes a criminal one.

The UAE is one of the world's most strictly regulated digital asset jurisdictions. Cryptocurrency is legal — but conducting P2P transactions in cash, operating without a VARA licence, or failing to demonstrate the source of funds can trigger immediate police involvement, account freezes, and money laundering allegations under Federal Decree-Law No. 20 of 2018.

Our work begins before the situation becomes unmanageable — at the investigation stage, before charges are formalised, when the legal position can still be shaped. We advise both parties in crypto disputes: buyers facing accusations of providing funds for illegal activity, and sellers accused of unlicensed exchange or money laundering.

Dr. Mohamed AlMur
Dr. Mohamed Abdalla Almur
Managing Partner
How it works in practice in the UAE

The police reason straightforwardly: there is a deal, there is cash, there is no license — meaning there are grounds for inspection. Both parties fall under scrutiny simultaneously. The seller explains the origin of the crypto and answers charges of unregistered financial activity. The buyer proves the legality of the cash and absence of intent to launder. The situation escalates sharply if there were many deals, sums exceed 180,000 AED, and settlements were in cash. Sometimes a single complaint from the other party is enough to open an investigation into both. What lies at the core of defense: the one-off nature of the deal, documented source of funds, and absence of intent — three arguments that determine the case outcome at an early stage.

What we advise on
Criminal defence
Defence against AML and money laundering allegations arising from crypto transactions
Representation at police interrogations and during pre-trial proceedings
Defence against unlicensed financial activity charges (VARA / SCA violations)
Challenging travel bans, account freezes, and asset seizures
Advice on source-of-funds documentation before engagement with police or regulators
Defending both buyers and sellers in P2P crypto disputes escalated to law enforcement
Parallel criminal and civil strategy in cases involving corporate or financial abuse
Recovery and disputes
Tracing and recovery of misappropriated or stolen cryptocurrency
Disputes with exchanges, counterparties, and intermediaries
Fraud schemes involving digital assets
Cross-border asset tracing and coordination with enforcement authorities
Typical matters
1A buyer and seller of USDT or other cryptocurrency are both detained by police after a cash P2P transaction — the seller is accused of conducting unlicensed exchange, the buyer of providing funds for illegal activity
2An individual who regularly exchanges cryptocurrency receives an AML investigation notice or has their bank account frozen without prior warning
3A business owner is summoned by police following a complaint from the other party in a crypto dispute — what began as a commercial matter is now criminal
4Cryptocurrency is transferred or diverted without authorisation and tracing is required across wallets and multiple jurisdictions
5A corporate conflict has acquired a parallel AML or crypto fraud dimension being used as leverage by the opposing party
6An exchange or P2P platform faces a regulatory inquiry from VARA or SCA regarding transaction patterns or AML compliance
Our approach

Considered strategy. Early intervention.

Egor Chernyshev
Egor Chernyshev
Partner
1Engage at the investigation stage — before charges are formalised and the legal position hardens
2Separate the transaction, the source of funds, and the intent — breaking the AML qualification at its foundation
3Establish whether the activity was isolated or systematic — this is the pivotal distinction in UAE crypto criminal law
4Coordinate criminal defence with any parallel civil or corporate proceedings
5Advise on source-of-funds documentation before any interaction with police or regulators
Related practices

Connected areas of expertise

High-stakes matters rarely sit inside a single legal box. The strongest strategy usually comes from seeing the whole conflict map.

Confidential consultation

A cryptocurrency matter in the UAE requires immediate attention.

Reach out directly to a senior lawyer. All enquiries are handled in strict confidence.