BSA LAW is proud to announce a landmark success achieved by its Criminal Department, which secured the acquittal of its clients in one of the most high-profile virtual asset cases in the United Arab Emirates.
The case began before the Court of First Instance, where BSA LAW’s clients were convicted of conducting virtual asset activities without a license, in addition to charges of money laundering. The court imposed both financial and criminal penalties. However, as the judgment lacked conclusive evidence to establish the elements of the money laundering offence, the firm appealed the decision, arguing that trading or investing in virtual assets without a license does not constitute money laundering unless the funds involved originate from an illicit source.
Despite presenting strong legal arguments, the Court of Appeal upheld the original verdict. BSA LAW then escalated the matter to the Court of Cassation, demonstrating both a misapplication of the law and a deficiency in the reasoning. As a result, the Court of Cassation overturned the judgment and referred the case back to the Court of Appeal for reconsideration.
During the retrial (Case No. 1000/2024), BSA LAW presented comprehensive legal defences and reassessed the facts from a focused legal perspective. The team relied on the provisions of Federal Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism along with the regulations governing virtual assets. On 15 May 2025, the Dubai Criminal Court of Appeal overturned the initial ruling and acquitted BSA LAW’s clients of all charges. The decision now stands as an important legal precedent in the field.
The court based its decision on the principle that while trading in virtual assets without a license may constitute a regulatory breach, it does not amount to money laundering unless it is proven that the funds were derived from or used to conceal an unlawful source.
This ruling represents a significant legal milestone and contributes to the evolving legal framework for virtual assets in the UAE. It reflects the judiciary’s careful balance between encouraging financial innovation and protecting the financial system.
This success reflects BSA LAW’s strong capabilities in navigating complex legal challenges related to virtual assets and anti-money laundering. The judgment also reinforces the firm’s commitment to protecting client rights and contributing to a fair, progressive legal environment that supports the UAE’s digital and financial development goals.
BSA LAW remains dedicated to delivering strategic and effective legal solutions that align with the UAE’s vision for innovation and regulatory excellence.