April 26, 2024

Instant Cross-Border Remittance Solution

by Soham Panchamiya, Pankhuri Malhotra, and Areeb Ahmad

in Case Studies


The Client is a cutting-edge fintech company that has developed a robust technological solution to facilitate seamless and instantaneous cross-border remittances. The Client sought to establish its innovative remittance service in the United Arab Emirates (UAE) by exploring potential partnerships with licensed financial institutions, as dictated by the stringent regulatory framework governing the region.

Client Challenge

The principal obstacle confronting the Client was navigating the intricate regulatory landscape overseen by the Central Bank of the UAE (CBUAE). Offering cross-border remittance services directly to consumers would mandate obtaining an Exchange Business license, a rigorous and capital-intensive undertaking that the Client sought to circumvent at this juncture. Concurrently, the Client aimed to leverage its technological prowess while eschewing the regulatory burdens associated with a licensed financial entity.

Strategies, Tactics, and Solutions

Our legal team conducted an in-depth analysis of the CBUAE’s regulatory framework, meticulously examining the nuances of the relevant regulations, including the Exchange Business Regulations, Retail Payment Systems Regulations, and the CBUAE’s Guidelines for Financial Institutions Adopting Enabling Technologies.

Through this comprehensive assessment, we devised a strategic partnership model wherein the Client would assume the role of a technology service provider to a CBUAE-licensed bank. This arrangement would enable the Client to integrate its cutting-edge remittance solution seamlessly into the bank’s existing infrastructure, facilitating instantaneous cross-border transactions without the need for the Client to obtain a license directly.

To safeguard the Client’s interests and mitigate regulatory risks, we crafted a robust framework outlining the roles, responsibilities, and compliance obligations of all stakeholders involved. To ensure that the Client acted as a technology service provider alone, we provided recommendations on the flow of funds through international banking networks. This framework ensured that the Client’s activities remained confined to providing technological infrastructure, while the licensed bank undertook the core remittance operations and adhered to the requisite regulatory mandates.


Our strategic analysis and partnership model will empower the Client to pursue its innovative cross-border remittance solution in the UAE market while navigating the intricate regulatory landscape. By positioning the Client as a technology service provider to a licensed financial institution, we enabled the Client to leverage its technological capabilities while mitigating regulatory risks and compliance burdens.

The proposed strategy will not only facilitate the Client’s market entry but also pave the way for future collaborations with other licensed entities, both in the UAE and internationally.

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