The FSB’s Global Crypto Review Misses the UAE, the Real Benchmark for Digital Asset Regulation

The Financial Stability Board (FSB) has released its Thematic Review on the Global Regulatory Framework for Crypto-Asset Activities (October 2025), a report assessing how G20 and FSB-member jurisdictions have implemented the FSB’s 2023 recommendations on regulating crypto-asset markets and stablecoins.

Framed as a “global” review, the report examines progress on regulatory clarity, cross-border coordination, and financial stability. Yet, it omits one of the world’s most active and advanced jurisdictions in the digital asset space — the United Arab Emirates (UAE).

Why the UAE Isn’t in the FSB Review

The UAE’s absence is not due to lack of progress, but rather a structural limitation. The FSB assesses only its member jurisdictions, which are primarily G20 economies and a few additional financial centers such as Singapore and Switzerland. The UAE is not an FSB member and, therefore, excluded from the review.

But this exclusion reveals a deeper gap. While the FSB tracks policy development, the UAE represents policy implementation in action. Its frameworks — across Dubai’s Virtual Assets Regulatory Authority (VARA), Abu Dhabi Global Market (ADGM), Dubai International Financial Centre (DIFC), and the UAE Central Bank — have already created one of the world’s most operationally mature ecosystems for digital assets.

By overlooking the UAE, the FSB’s “global” perspective fails to account for the jurisdiction that has arguably achieved what many G20 members are still drafting.

Did the FSB Bring Anything the UAE Doesn’t Already Know?

The FSB’s key findings urge jurisdictions to establish:

• Clear and consistent licensing regimes for VASPs,
• Transparent stablecoin reserve management,
• Strong cross-border supervisory cooperation, and
• Enhanced operational resilience.

Yet all these priorities are already embedded in the UAE’s framework.
The VARA rulebook defines each virtual asset activity with exceptional precision. ADGM’s FSRA has regulated digital asset activity since 2018, covering custody, token issuance, and DeFi participation. The UAE Central Bank’s Payment Token Services Regulation, issued in 2024, establishes a full licensing model for stablecoins — making the UAE one of the few jurisdictions with a central bank-approved crypto regulation.

Where the FSB calls for coordination, the UAE has already implemented it. VARA, ADGM, and the Central Bank operate with inter-regulatory alignment — a feature the FSB identifies as missing in many G20 markets.

Infrastructure Stress Testing: The Missing Link in the FSB Review

Despite emphasizing risk management, the FSB’s report does not address infrastructure stress testing for virtual asset service providers. There is no framework for assessing how exchanges, custodians, or payment token issuers would perform under transaction surges, cyberattacks, or market stress scenarios.

In contrast, the UAE has already operationalized these principles. VARA mandates IT resilience audits and business continuity plans, ADGM requires technology governance and operational risk frameworks, and the Central Bank supervises real-time resilience and liquidity safeguards for payment token licensees.

While the FSB discusses operational soundness as a goal, the UAE enforces it as a standard.

The Big Picture: A “Global” Review Missing Its Global Leader

The FSB’s thematic review may serve as a valuable snapshot for its members, but it falls short of reflecting the real state of global digital asset regulation. By excluding the UAE — a jurisdiction with live licensing, active exchanges, and regulated stablecoin infrastructure — the review overlooks what is arguably the world’s most advanced example of banking and digital asset convergence.

As the crypto and financial sectors merge, global leadership will not be defined by membership lists but by measurable progress. The FSB’s review captures the conversation — but the UAE is already shaping the outcome.