Where UAE law has moved on since the exam material, what the exam still tests, and how Bourse Prep keeps the two apart.
The UAE FRR exam follows the study material for syllabus version 4.2. That material describes laws and regulator decisions as they stood when it was written, and several have since been replaced or amended, so the answer the exam marks as correct is not always the rule in force today. Bourse Prep keeps the exam answer in every question, because that is what the paper tests. Where the law has moved on, we add an Update note naming the later law or decision and, where known, the date it took effect. This page brings those notes together by theme. The regulator is the authority on current law; Bourse Prep explains the exam material. For anything beyond the exam, rely on the regulator's published rules.
Chapter 1 · from 1 January 2026
In the exam material: Federal Law No. 4 of 2000, with the Securities and Commodities Authority (SCA) as regulator. Later: Federal Decree-Laws No. 32 and 33 of 2025; the SCA became the Capital Market Authority.
Chapter 1 is built on Federal Law No. 4 of 2000, which created the SCA, set its objectives and board, and laid down core market rules on licensing, recording deals, transfers of ownership and insider dealing. From 1 January 2026 two federal decree-laws issued in 2025 took the place of that law, and the regulator now operates as the Capital Market Authority. The study material still describes the earlier law and uses the SCA name across the syllabus.
Answer with the SCA and Federal Law No. 4 of 2000 as the study material presents them, including the board terms, reporting cycle and market rules set by that law.
Chapter 1 · from 29 July 2022
In the exam material: SCA Rulebook as issued in 2021: a single minimum of AED 50 million in paid-up capital. Later: Decision No. 18 of 2022: a separate capital figure for each activity in the category.
The Rulebook as issued in 2021 gave Category 2 one paid-up capital minimum of AED 50 million, the same figure as Category 3. Decision No. 18 of 2022 replaced that single figure with an amount for each activity, so that fund management, for example, was set at AED 1 million. The exam keeps the 2021 figures.
Use AED 50 million for Category 2, alongside AED 30 million for Category 1 and AED 5 million for Category 4, as the 2021 Rulebook set them.
Chapter 1 · from 15 April 2023
In the exam material: SCA Rulebook as issued in 2021: no minimum paid-up capital. Later: Decision No. 23 of 2023: a paid-up capital floor of AED 500,000.
The 2021 Rulebook gave Category 5 (Arrangement and Advice, also known as Ranking and Advice) no paid-up capital requirement, unlike Categories 1 to 4. Decision No. 23 of 2023 introduced a floor of AED 500,000 for this category. The exam is based on the 2021 position.
For the exam, Category 5 has no minimum paid-up capital.
Chapter 4 · from 2023, then 2026
In the exam material: SCA Crypto Assets Activities Regulation, Chairman's Decision No. 23/RM of 2020. Later: SCA Decisions No. 26/RM and 27/RM of 2023, then the Capital Market Authority Virtual Assets Framework (Resolution No. 4 of 2026).
The crypto asset section of Chapter 4 tests the 2020 regulation: offers and listings, disclosure, custody, fundraising limits, exchange licensing, qualified investors, exchange crimes and the Authority's supervisory and sanction powers. The SCA replaced those rules in 2023 with two new decisions, and in 2026 the Virtual Assets Framework of the Capital Market Authority superseded them. Which rules apply today also turns on the type of asset, the activity concerned and the place where it is carried on.
Answer crypto questions from Chairman's Decision No. 23/RM of 2020, including its AED 350,000 fundraising cap and its qualified investor tests.
Chapter 5 · from 14 October 2025
In the exam material: Federal Decree-Law No. 20 of 2018. Later: Federal Decree-Law No. 10 of 2025.
Chapter 5 teaches the money laundering and terrorist financing offences, and the duties of financial institutions and designated non-financial businesses and professions, from Federal Decree-Law No. 20 of 2018. Federal Decree-Law No. 10 of 2025 replaced it from 14 October 2025. Some penalties changed and some article numbers moved, so an article number in the study material may not match the new law.
The exam still tests the offences and duties as the 2018 law states them, with its article numbers.
Chapter 5 · from 14 October 2025
In the exam material: Federal Decree-Law No. 20 of 2018, penalty provisions. Later: Federal Decree-Law No. 10 of 2025, penalty provisions.
The new law keeps some penalties and changes others. For the basic laundering offence the fine band of AED 100,000 to AED 5,000,000 and the ten-year maximum prison term stay the same, but a minimum term of one year has been added. Terrorist financing now carries a fine of AED 1 million to AED 10 million, a legal person faces AED 5 million to AED 100 million, and publishing a summary of the judgment is now at the court's discretion rather than compulsory.
Learn the penalties as the 2018 law sets them, for example AED 300,000 to AED 10,000,000 for terrorist financing and AED 500,000 to AED 50,000,000 for a legal person.
Chapter 5 · from 14 December 2025
In the exam material: Cabinet Decision No. 10 of 2019. Later: Cabinet Decision No. 134 of 2025.
Cabinet Decision No. 10 of 2019 is the implementing regulation behind most of the practical AML material in Chapter 5: customer due diligence and its thresholds, beneficial ownership, prohibited relationships, PEPs, suspicious transaction reports, internal controls, the compliance officer and record keeping. Cabinet Decision No. 134 of 2025 replaced it from 14 December 2025. The detail of what changed sits outside the exam material, so check the new decision before relying on any figure in practice.
The exam still uses the 2019 decision, including the AED 55,000 and AED 3,500 due diligence thresholds, the 25% ownership test and the five-year record period.
Chapter 7 · from February 2025
In the exam material: The ADX Clearing, Settlement and Depository Department (CSD), a department within ADX. Later: Two ADX group companies: AD Clear as central counterparty and AD CSD as central securities depository.
The Chapter 7 rules treat clearing, settlement, investor numbers, deposits and pledges as work done by the CSD Department inside ADX. In February 2025 ADX transferred this work to two companies in its group, AD Clear acting as central counterparty and AD CSD as central securities depository. The exam describes the earlier departmental structure.
Answer post-trade questions on the CSD Department as the study material describes it, for example its 15-year retention of ownership transfer records.
Specific rules where the answer the exam expects differs from what applies today. Learn the exam rule for the exam; use the later development at work, after checking the current text.
| Ch. | Topic | The exam rule | Later development | Reference |
|---|---|---|---|---|
| 1 | Who regulates the markets | The SCA, incorporated in Abu Dhabi under Federal Law No. 4 of 2000, is an independent public authority, with its own legal personality, budget and administration, that regulates and supervises the securities and commodities markets. | From 1 January 2026 the regulator is the Capital Market Authority, and Federal Decree-Laws No. 32 and 33 of 2025 took the place of the 2000 law. | Federal Decree-Laws No. 32 and 33 of 2025 1 January 2026 |
| 1 | SCA board terms and reporting | Board members other than the chief executive serve a four-year term that can be renewed once, and the board reports on market activity to the Cabinet of Ministers every six months. | From 1 January 2026 Federal Decree-Laws No. 32 and 33 of 2025 replaced the 2000 law and the SCA became the Capital Market Authority, so check the current law for the board arrangements that apply now. | Federal Decree-Laws No. 32 and 33 of 2025 1 January 2026 |
| 1 | Recording deals in listed securities | Every deal in listed securities has to be recorded through the market under its rules, an unrecorded deal is null and void, and the issuer must carry out its share of the transfer steps without delay. | From 1 January 2026 Federal Decree-Laws No. 32 and 33 of 2025 replaced the 2000 law and the SCA became the Capital Market Authority, so check the current law for the recording and transfer rules in force. | Federal Decree-Laws No. 32 and 33 of 2025 1 January 2026 |
| 1 | Dealing by insiders of a listed company | The chairman, directors, general manager and staff of a listed company can trade its shares only if the board approves the deal and it is disclosed to the market, and without both the deal is null and void. | From 1 January 2026 Federal Decree-Laws No. 32 and 33 of 2025 replaced the 2000 law and the SCA became the Capital Market Authority, so check the current law for the dealing restrictions in force. | Federal Decree-Laws No. 32 and 33 of 2025 1 January 2026 |
| 1 | Setting up a market | A securities and commodities market takes one of two legal forms, a local public establishment or a public joint-stock company, and cannot start trading before the Authority grants its licence. | From 1 January 2026 Federal Decree-Laws No. 32 and 33 of 2025 replaced the 2000 law and the SCA became the Capital Market Authority, so check the current law for the licensing conditions in force. | Federal Decree-Laws No. 32 and 33 of 2025 1 January 2026 |
| 1 | Category 2 minimum capital | The 2021 Rulebook sets one minimum for Category 2, Dealing in Investment: AED 50 million of paid-up capital. | Since 29 July 2022 the capital has been set activity by activity, with fund management, for instance, at AED 1 million. | Decision No. 18 of 2022 29 July 2022 |
| 1 | Category 5 minimum capital | The 2021 Rulebook sets no paid-up capital floor for Category 5, Arrangement and Advice (also known as Ranking and Advice). | Since 15 April 2023 a firm in this category must hold at least AED 500,000 of paid-up capital. | Decision No. 23 of 2023 15 April 2023 |
| 4 | Crypto fundraising cap | Unless a crypto fundraising is open only to qualified investors, each client's investment is capped at AED 350,000 or the equivalent, and the Authority may revise that amount. | The 2020 regulation gave way to new SCA rules in 2023 and then to the Capital Market Authority's Virtual Assets Framework in 2026, so check the current framework for any limit that applies now. | SCA Decisions No. 26/RM and 27/RM of 2023, then the Capital Market Authority Virtual Assets Framework (Resolution No. 4 of 2026) 2023, then 2026 |
| 4 | What counts as a security token | A security token is a crypto asset whose rights resemble those of a share or a bond, for example ownership, profit or repayment rights, and every other crypto asset is a commodity token. | The 2020 regulation gave way to new SCA rules in 2023 and then to the Capital Market Authority's Virtual Assets Framework in 2026, so check the current framework for the categories used now. | SCA Decisions No. 26/RM and 27/RM of 2023, then the Capital Market Authority Virtual Assets Framework (Resolution No. 4 of 2026) 2023, then 2026 |
| 4 | Offering security tokens | Only an entity set up in the UAE, or in one of the UAE's financial free zones, may offer security tokens, and an offer limited to qualified investors needs only its documents lodged with the Authority, while one open to other investors needs the Authority's approval in advance. | The 2020 regulation gave way to new SCA rules in 2023 and then to the Capital Market Authority's Virtual Assets Framework in 2026, so check the current framework for the offering rules in force. | SCA Decisions No. 26/RM and 27/RM of 2023, then the Capital Market Authority Virtual Assets Framework (Resolution No. 4 of 2026) 2023, then 2026 |
| 4 | Custody of client crypto assets | A custodian keeps client crypto assets apart from its own, may not lend them, must hold the same asset in the amount it owes clients, and may not let any one person authorise actions alone. | The 2020 regulation gave way to new SCA rules in 2023 and then to the Capital Market Authority's Virtual Assets Framework in 2026, so check the current framework for the custody rules in force. | SCA Decisions No. 26/RM and 27/RM of 2023, then the Capital Market Authority Virtual Assets Framework (Resolution No. 4 of 2026) 2023, then 2026 |
| 4 | Qualified investor test for individuals | For crypto purposes an individual counts as a qualified investor with AED 4 million of net equity, not counting the main home, yearly income of AED 1 million or more, and either a declaration of adequate knowledge and experience of investing or being represented by a firm the Authority licenses. | The 2020 regulation gave way to new SCA rules in 2023 and then to the Capital Market Authority's Virtual Assets Framework in 2026, so check the current framework for the investor tests used now. | SCA Decisions No. 26/RM and 27/RM of 2023, then the Capital Market Authority Virtual Assets Framework (Resolution No. 4 of 2026) 2023, then 2026 |
| 4 | Sanctions under the crypto rules | The Authority can suspend a licensed firm's activity for up to one year, and a responsible individual, such as a board member or approved employee, for up to two months. | The 2020 regulation gave way to new SCA rules in 2023 and then to the Capital Market Authority's Virtual Assets Framework in 2026, so check the current framework for the sanctions that apply now. | SCA Decisions No. 26/RM and 27/RM of 2023, then the Capital Market Authority Virtual Assets Framework (Resolution No. 4 of 2026) 2023, then 2026 |
| 5 | Money laundering as an offence | Where a person knows funds are criminal proceeds, money laundering covers converting or moving them to disguise their source as well as acquiring, holding or using them, and it is a stand-alone crime that does not wait on punishment for the predicate offence. | Federal Decree-Law No. 10 of 2025 replaced the 2018 law from 14 October 2025 and changed some penalties and article numbers, so check the new law for the current wording and article references. | Federal Decree-Law No. 10 of 2025 14 October 2025 |
| 5 | Due diligence thresholds | Customer due diligence is triggered by an occasional transaction, or apparently linked transactions, totalling AED 55,000 or more, by an occasional wire transfer of AED 3,500 or more, and at any amount where there is suspicion of crime or doubt about identity data already held. | Cabinet Decision No. 134 of 2025 replaced the 2019 decision from 14 December 2025, so check the new decision for the thresholds that apply now. | Cabinet Decision No. 134 of 2025 14 December 2025 |
| 5 | Beneficial ownership | A firm looks through a corporate customer to any natural person who, alone or jointly, holds a controlling ownership stake of 25% or more, and verifies the senior management officers instead if that owner cannot be verified. | Cabinet Decision No. 134 of 2025 replaced the 2019 decision from 14 December 2025, so check the new decision for the ownership test in force. | Cabinet Decision No. 134 of 2025 14 December 2025 |
| 5 | Politically exposed persons | Taking on or keeping a foreign PEP requires sign-off by senior management, reasonable measures to find out where the funds come from and closer ongoing monitoring, and for a domestic PEP these steps apply when the relationship is high risk. | Cabinet Decision No. 134 of 2025 replaced the 2019 decision from 14 December 2025, so check the new decision for the PEP measures in force. | Cabinet Decision No. 134 of 2025 14 December 2025 |
| 5 | Record keeping | Transaction and CDD records, including ID copies, account files, correspondence and STRs, are kept for a minimum of five years, counted from the end of the relationship or the completion of the transaction. | Cabinet Decision No. 134 of 2025 replaced the 2019 decision from 14 December 2025, so check the new decision for the retention period in force. | Cabinet Decision No. 134 of 2025 14 December 2025 |
| 5 | Administrative fines for AML breaches | A supervisory authority may fine a financial institution or a designated non-financial business or profession between AED 50,000 and AED 5,000,000 for each violation, alongside sanctions such as warnings, limits on activity and cancellation of the licence. | Federal Decree-Law No. 10 of 2025 replaced the 2018 law from 14 October 2025 and changed some penalties and article numbers, so check the new law for the range that applies now. | Federal Decree-Law No. 10 of 2025 14 October 2025 |
| 5 | Basic money laundering penalty | The basic offence carries up to ten years in prison, a fine of AED 100,000 to AED 5,000,000, or both, and an attempt is punished in the same way as the completed offence. | Under the new law the ten-year maximum and the fine band stay the same, but a minimum prison term of one year has been added. | Federal Decree-Law No. 10 of 2025 14 October 2025 |
| 5 | Terrorist financing penalty | Financing terrorism with funds draws a prison sentence of life, or a fixed term of no less than ten years, plus a fine between AED 300,000 and AED 10,000,000. | Under the new law terrorist financing carries a fine of AED 1 million to AED 10 million. | Federal Decree-Law No. 10 of 2025 14 October 2025 |
| 5 | Fines on a legal person | Where its representatives, managers or agents intentionally commit laundering or terrorist financing on its behalf, a legal person faces a fine from AED 500,000 up to AED 50,000,000. | Under the new law the range for a legal person is AED 5 million to AED 100 million. | Federal Decree-Law No. 10 of 2025 14 October 2025 |
| 5 | Publishing the judgment | After a conviction of a legal person, the court is required to have a judgment summary published, with the convicted party paying the cost. | Under the new law publication is at the court's discretion rather than compulsory. | Federal Decree-Law No. 10 of 2025 14 October 2025 |
| 5 | Failing to report a suspicion | A person who fails to report a suspicion, or is grossly negligent in applying the reporting procedures, faces imprisonment, a fine of AED 100,000 to AED 1,000,000, or both. | Federal Decree-Law No. 10 of 2025 replaced the 2018 law from 14 October 2025 and changed some penalties and article numbers, so check the new law for the penalty that applies now. | Federal Decree-Law No. 10 of 2025 14 October 2025 |
| 5 | Tipping off | Warning anyone that a report has been or will be made is tipping off, punishable by at least six months in prison, a fine of AED 100,000 to AED 500,000, or both. | Federal Decree-Law No. 10 of 2025 replaced the 2018 law from 14 October 2025 and changed some penalties and article numbers, so check the new law for the penalty that applies now. | Federal Decree-Law No. 10 of 2025 14 October 2025 |
| 7 | Who clears and settles ADX trades | The ADX CSD Department clears and settles trades for clearing members, records ownership transfers electronically, and keeps transfer data with its supporting documents for at least 15 years. | In February 2025 ADX placed these services in two group companies, AD Clear as central counterparty and AD CSD as central securities depository. | ADX group structure: AD Clear and AD CSD February 2025 |
| 7 | Investor numbers, deposits and pledges at ADX | An investor needs an investor number from the CSD Department before opening a broker account, and a pledge can be made only over securities already held on deposit with the CSD Department, becoming effective after registration on the automated clearing system. | In February 2025 the depository and clearing services were taken out of the ADX department and placed in two group companies, AD CSD and AD Clear. | ADX group structure: AD Clear and AD CSD February 2025 |
Checked against the verified Bourse Prep FRR question bank, 11 October 2026. Dates are as the question bank's Update notes state them; where a note gives no date, none is shown.
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