The fine line between Online marketplaces and Payment service providers - UAE Regulation as a case study

Operators of online marketplaces tend to have identity crises in jurisdictions with recently enacted payment services regulation. They have the temptation to wish away the fact that their businesses are ultimately payment services businesses. This brief note examines recent developments in UAE financial regulation that bring further clarity about the distinction between “pure tech plays” and payment services in the UAE and outlines four different courses of action for navigating the gray area.