J. awan & partners

Eid Al Adha Mubarak from all of us at j. awan & partners.

This occasion is a reminder of what sits at the heart of everything we do: sacrifice, integrity and service to others. Across nine offices and four continents, our team pauses today to reflect on those values and to wish our clients, partners and communities a blessed and joyful Eid.

Eid Mubarak.

US and UAE stablecoin regulation, in one conversation.

j. awan & partners and Winston & Strawn LLP are convening a live webinar on the practical reality of stablecoin regulation across the US and the UAE. The frameworks are in place. The GENIUS Act is law. The UAE's three stablecoin regimes are live. The question now is what they actually require, and what that means for firms making real decisions on issuance, structure, and cross-border operation.

The speakers:
Jehanzeb Awan, Founder and CEO, j. awan & partners and azakaw
Yulia Makarova, Partner, Winston & Strawn LLP
Thania Charmani, Partner, Winston & Strawn LLP
Konstantinos Adamos, Of Counsel, Winston & Strawn LLP

What we will cover: the US dual federal and state regime in practice under the GENIUS Act, the OCC national trust bank charter race, and the yield prohibition. The three live UAE regimes (CBUAE, VARA, ADGM and FSRA) and what drives the domicile decision beyond the headline reserve rules. The AED stablecoin market: what has moved, what has not, and where regulatory attention is focused. Live Q&A.

For legal, compliance, and regulatory professionals at financial institutions, fintechs, and crypto-asset businesses operating across the GCC, the US, and the UK.

Register today. Submit your questions at registration and we will work through them during the session.

Register here: https://luma.com/1mknqjn1

VARA published the most detailed virtual asset derivatives rulebook in the region. Here's what it requires from your compliance function.

Part V of the Exchange Services Rulebook, Version 2.1, is effective immediately. It establishes a purpose-built framework for Exchange-Traded Derivatives — eleven obligation areas, prescriptive requirements, and no grandfathering for firms operating under pilot arrangements.

Most VASPs in this space know the framework dropped. Fewer have mapped their current operations against what it actually requires.

Dowload our Guide to learn what this means in practice and what your compliance function should be doing now.

🔗 https://www.jawanpartners.com/vara-etd-framework

CBUAE's new AML guidance just expanded your compliance obligations — here's what changed

On 16 April, the CBUAE issued updated AML/CFT/CPF guidance covering three areas that most compliance teams are not yet set up for:

1. Proliferation Finance — dynamic risk intelligence beyond static sanctions lists
2. Trade-Based Money Laundering — integrating AML with trade, logistics, and customs data
3. Enhanced KYC under FATF alignment — raising the bar on customer due diligence

This isn't a future obligation. It's live.

For CBUAE-regulated entities — payment firms, finance companies, exchange houses — this means your AML programme likely needs updating before your next inspection.

At j. awan & partners, our outsourced MLROs and Compliance Officers are already incorporating these changes into client programmes.

If your MLRO hasn't flagged this guidance to you yet, that's a signal worth paying attention to.

Contact us and request a a CBUAE AML health check → https://www.jawanpartners.com/contact-us

j. awan & partners × Winston & Strawn LLP

The stablecoin frameworks are no longer forthcoming. They are here.
The GENIUS Act is law. The UAE's three regimes, CBUAE, VARA, and ADGM/FSRA are live. The question now is what they actually require, and what that means for firms making real decisions.

On 3 June, we are hosting a practitioner-level session with Winston & Strawn LLP on exactly that.

Stable. Issuing Stablecoins Across the US and the UAE: What the Frameworks Demand in Practice

📅 Tuesday, 3 June 2026
🕔 5:00 PM Dubai · 2:00 PM London · 9:00 AM New York
⏱ 45 minutes · Zoom
🎟 Complimentary

Register now: https://luma.com/1mknqjn1

May 2026 brings a wave of regulatory activity across the GCC.

Here are the updates across UAE regulators that should be on every compliance team's radar:

• CBUAE
- Updated AML/CFT/CPF guidance now covers Proliferation Finance, Trade-Based ML, and enhanced KYC under FATF alignment

• VARA
- All Virtual Asset Service Providers (VASPs) are required to incorporate the findings of the most recent UAE National Risk Assessment, as well as the provisions of the updated AML/CFT Law and relevant Cabinet Decisions (No. 10 of 2025 and No. 134 of 2025), into their AML/CFT framework and broader operational compliance framework.

• ADGM
- The maintenance of its Cybersecurity Framework following the update to the FSRA Cyber Risk Management rules and the mandatory requirement for the implementation of a cybersecurity framework applicable to all ADGM entities (FSRA & RA).
- FSRA Digital Asset Regulatory Framework amendments + staking framework now live.
- Consideration and adherence to the Guidance on the AML Business Risk Assessment (BRA) for an effective and robust and well-documented AML Business Risk Assessment framework.

• DFSA
- CP171 miscellaneous amendments published

Each of these creates obligations, and deadlines.

At j. awan & partners, our compliance teams work across all GCC regulators. We help regulated firms stay ahead of these changes, not react to them.

Applying for a financial services licence in the GCC?

DFSA. FSRA. VARA. CBUAE. SAMA. CMA.

Each regulator has different requirements, different timelines, and different expectations for your business plan, compliance framework, and senior management.

At j. awan & partners, we manage the end-to-end licence application process: from business plan drafting to regulator liaison to post-licence compliance setup.

What makes our approach different:

→ We don't just get you licensed. We set up your outsourced compliance function from day one: MLRO, Compliance Officer, Finance Officer, Company Secretary.
→ One provider. All GCC regulators. No gaps between licensing and ongoing compliance.
→ Our team has led applications across every major GCC financial services regime.

If you're planning to enter the UAE or Saudi market, or expanding an existing licence, talk to us before you file.

🔗 https://www.jawanpartners.com/contact-us

Most GCC financial institutions built their cloud strategy around a single assumption: that the infrastructure would always be available.

March tested that assumption directly. Two of three AWS Availability Zones in the UAE disrupted simultaneously. Data residency requirements meant migrating workloads to other regions was not a simple option. For cloud-native firms with no secondary provider and no tested failover, there was no plan to run.

The structural issue predates the conflict. Concentrating critical workloads with a single provider in a single geography means a single event can affect the entire operation at once. Regulators across the region, from CBUAE to SAMA to the DFSA, have been pressing on this. March gave those conversations considerably more urgency.

The question for most institutions is not whether to act, but where to start.

Mark Scott, Head of Risk Practice at j. awan & partners, sets out the four questions every GCC financial institution should be able to answer now.

Read the full article: www.jawanpartners.com/insights/when-the-cloud-goes-dark
Get in touch: www.jawanpartners.com/contact-us

Could you identify your firm's critical business services in the next 48 hours?

Under the DFSA's proposed operational resilience framework, every Authorised Person in DIFC will be required to do exactly that: carry out a regular exercise to identify which business services, if disrupted, would cause material harm to clients or to financial stability in the DIFC.

Most firms assume they already know the answer. Fewer have the documentation to demonstrate it to a regulator.

Critical business services mapping is not a high-level list of what your firm does. It requires examining dependencies on people, systems, third parties and data, identifying where a single point of failure could bring a service down entirely. It requires Governing Body sign-off. And it is the gateway requirement: until you have completed it, the rest of the framework cannot be built.

The consultation closes 26 May 2026. Implementation will follow.

j. awan & partners supports firms with operational resilience assessments, business continuity planning and risk framework implementation. If you would like to understand what this means for your firm specifically, our risk practice can help.

Find out more: www.jawanpartners.com
Get in touch: www.jawanpartners.com/contact-us

The Qatar corporate tax return deadline is 30 April 2026.

For entities operating in Qatar, the filing window for the financial year ending 31 December 2025 closes this week. With multiple requirements in scope, now is the time to make sure everything is in order.

Submissions must be made via the Dhareeba Tax Portal under Qatar's Income Tax Law (Law No. 24 of 2018).

Three things to confirm before you file:

Audited financials are required if capital exceeds QAR 200,000 or revenue exceeds QAR 500,000.
Transfer pricing declarations must accompany the return where related-party thresholds are met.
QFC-licensed entities have separate obligations under QFC regulations.

Our team is here to help if you need support: www.jawanpartners.com/contact-us

26 May 2026. That is when DFSA-regulated firms must have identified their important business services and set board-approved impact tolerances under CP 170.

The question regulators are asking is not whether a business continuity plan exists. It is whether the board understands which services, if disrupted, would cause intolerable harm, and whether the thresholds that define that have been approved at the right level.

Most firms have documentation. Far fewer have clarity.

To discuss where your firm stands ahead of the 26 May deadline, contact us at www.jawanpartners.com/contact-us