Christine Abou Assali, co-chair of the Policy and Regulation Working Group at the Mena Fintech Association and partner at Alem Associates, joins Wall Street to Mena to discuss the intersection of law, regulation and fintech innovation in the Gulf. Drawing on a career that began in derivatives and securitizations, she explains why the complexity of financial products makes lawyers and regulators more important than ever, and why in fintech, they are actively shaping the market rather than just reacting to it. For founders trying to navigate the UAE’s multi-regulator landscape, FSRA, VARA, DFSA and more, she offers a practical three-question framework: what is your product, what is your activity, and who are your customers? She also pushes back firmly on the idea that compliance costs stifle innovation, arguing that sustainable innovation is impossible without it, and that the UAE’s risk-based, proportionate regulatory approach is designed to support founders at every stage.
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Compliance is Not the Enemy: Christine Abou Assali on Fintech Regulation in the UAE
I'm very excited to be joined in the studio today by Christine Abou Assali, co-chair of the Policy and Regulation Working Group at the Mena Fintech Association and partner at Alem Associates. Christine, thanks so much for joining us today.
Thank you very much for having me. So as mentioned, you wear multiple hats — you're a partner at a law firm and you chair this policy working group. What initially drew you to this intersection of law, technology and finance?
I was always drawn to complex areas of law. I started my career working on derivatives and securitizations. I remember one of my first job interviews being asked: what's the difference, from a consumer protection perspective, between selling shoes and selling financial products? With shoes, you know exactly what they're designed to do, you know what can go wrong, you can even try them on. A financial product is far more complex — the risk can be opaque, and you can really lose a lot, including your savings. The more complex a product is, the more important the role of lawyers and regulators becomes. And in fintech today, that is even more accentuated — because regulators and lawyers are actively shaping the market, not just reacting to it. We see this with companies choosing to set up in jurisdictions where the regulatory framework is clear and certain, which is one of the key reasons so many are coming to ADGM, the DIFC and the UAE.
That's a great segue. You've just taken on the role of co-chair of the Policy and Regulation Working Group at the Mena Fintech Association. What are some of the concrete problems you're trying to solve?
At the Mena Fintech Association, the working group is really about bringing regulators and innovators together to move forward constructively. Innovators are building great products and regulators are there to support them while protecting the markets. Our role is to create structured, constructive dialogue — to solve issues as they arise and, more broadly, to build a culture where compliance is seen as an enabler for business rather than a barrier. Companies that engage with these questions early tend to thrive and build something sustainable.
Let's talk about that regulatory landscape. In the Middle East we have a number of regulators — the FSRA, VARA, the DFSA. For a founder watching this, how do they even begin to navigate all of that?
In the UAE we are actually lucky to have multiple regulators — it's a strength, at least for now. I would tell a founder to start by asking themselves three questions. First: what is my product? Are you processing data for customers, handling client money, storing value? Second: what is my activity? If you're in digital assets, are you a broker-dealer, are you enabling buyers and sellers to exchange on a platform, or are you providing safe custody? Third: who are my customers and where are they? Are they retail investors, professional clients or market counterparties? Are they based only in the DIFC or across the wider UAE? Once you've worked through those questions, speak with your advisor — together, those answers will help you determine which regulator or regulators to approach.
So in your view, it's better to do that internal work first before approaching regulators?
Regulators in the UAE are very approachable and they genuinely want to engage — so by all means reach out. And you may well need approval from more than one regulator, which is often the case here. But do this work first. Don't just pick one regulator without thinking it through, because you may find yourself having to comply with additional regulations you hadn't anticipated at the outset — and that is when regulation can start to feel burdensome.
Final question. There's been a wave of new crypto licensing rules in the UAE, with significant fines for unlicensed players. Do you worry that compliance costs could start to crowd out innovation?
Not at all — because compliance is an essential part of innovation. You cannot have sustainable innovation without it. We wouldn't allow a doctor to operate on a patient without a medical degree and years of training. Similarly, we cannot allow an unlicensed player to operate in financial markets. Now, if regulations are disproportionate or inadequate, that can add unnecessary costs. But in the UAE, the regulations are proportionate and risk-based. If you're operating in a sandbox with limited activity and limited stakeholders, the compliance burden is low. If you are fully operational and holding retail client money, the compliance burden is higher — and that is completely understandable. Compliance is necessary. The real question is whether the regulations are adequate, proportionate and risk-based — and in the UAE, I believe they are.
Thank you so much for coming on the show. It was really great to have your views from both the legal and innovation perspective.
Likewise. Thank you very much.
