April 26, 2024

Send-Now-Pay-Later Platform

by Soham Panchamiya, Pankhuri Malhotra, and Areeb Ahmad

in Case Studies


The Client, a fintech start-up, approached our firm seeking strategic advice on launching its innovative “Send-Now-Pay-Later” (SNPL) lending product in the United Arab Emirates (UAE). This product aimed to provide short-term credit facilities to migrant workers, enabling them to send remittances home while repaying the loan in instalments.


The primary challenge was navigating the UAE’s intricate regulatory landscape and ensuring compliance with the Central Bank of the UAE (CBUAE) regulations. The existing regulatory framework did not explicitly cover SNPL products, posing a significant obstacle to the Client’s proposed business model.

Strategies, Tactics, and Solutions

Our team conducted an in-depth analysis of the CBUAE’s Finance Companies Regulations, Guidelines for Financial Institutions adopting Enabling Technologies, and other relevant regulatory frameworks. We proposed the establishment of a regulatory sandbox, allowing the Client to test its product under controlled conditions while adhering to existing regulations.

We suggested expanding the definition of “short-term credit” within the CBUAE’s regulations to encompass SNPL products. Additionally, we outlined a tripartite agreement structure where a UAE Bank would handle lending operations, the Client would provide technological infrastructure as an outsourcing partner and a UAE Exchange House would serve as the customer-facing platform.

Our comprehensive analysis also covered risk assessment, data protection, and ethical AI guidelines, ensuring a robust and compliant implementation.


Our strategic advice is empowering the Client to navigate the complex regulatory landscape and present a well-structured proposal to the CBUAE, the UAE Exchange House, and the UAE Bank. This proposal includes a regulatory sandbox, an expanded definition of short-term credit, and a detailed framework for SNPL regulations.

Our firm’s expertise in regulatory analysis and drafting ensured that the Client could confidently approach the relevant authorities with a solid foundation for launching its innovative SNPL product in the UAE. The tripartite agreement drafted by our firm will further solidify the proposed partnership structure, roles and responsibilities of each entity while mitigating risks and ensuring regulatory compliance.

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