Facilitating a 40% Foreign Investment in a UAE Exchange House: A Regulatory-Compliant Deal

November 29, 2025by Vipul Kulshreshtha0

Background

A long-established UAE exchange house regulated by the Central Bank of the UAE planned to bring in a well-known US based financial services company as a strategic investor. The exchange house intended to sell 40 percent of its shares to the US investor in return for a significant capital infusion. This partnership was expected to strengthen the company’s financial position and support new growth plans. Since the business operated in a heavily regulated sector, every commercial decision needed to comply with CBUAE rules.

Our Role

We acted as the legal advisors for the exchange house throughout the transaction. Our work involved a mix of regulatory guidance, deal structuring and detailed drafting support. In particular, we:

  • Reviewed CBUAE regulations to identify the limits and requirements relevant to foreign ownership, shareholder rights and governance.
  • Developed a compliant deal framework and ensured that the Letter of Intent, Term Sheet, Share Sale Agreement and Shareholders Agreement reflected CBUAE expectations.
  • Drafted, revised and negotiated all transaction documents with the US investor’s legal team, addressing several commercial and regulatory concerns along the way.
  • Updated the constitutional documents of the exchange house to incorporate the rights of the new investor while keeping the company aligned with regulatory norms.
  • Joined discussions with both parties to help bridge commercial expectations and regulatory obligations.

This Case Study is a Part of Our Mergers and Acquisition Services.

Key Challenges

Two major commercial issues required careful handling. The first involved the US investor’s request for a disproportionate distribution of dividends. This raised questions under the regulatory framework and needed a structure that would satisfy both the investor and the regulator. The second related to governance. The investor wanted enhanced board rights, and a list of veto matters to protect its investment. These requests had to be balanced with CBUAE requirements on control, shareholder involvement and management oversight.

Both issues needed detailed analysis because even minor changes in governance or distribution rights can affect regulatory approvals for companies supervised by the Central Bank of the UAE.

Outcome

We worked closely with the exchange house management and engaged in regular discussions with the investor’s team to reach a structure that was commercially acceptable and regulator friendly. The dividend mechanism was aligned in a manner that met the investor’s expectation without breaching any regulatory rules. The board composition and veto matters were also reshaped to give the investor comfort while ensuring that the company stayed within the compliance boundaries set by CBUAE.

The transaction was completed successfully. The exchange house secured the planned capital infusion, welcomed a strong international partner and maintained full regulatory compliance. Our involvement allowed the deal to move forward smoothly and helped both parties achieve their business goals.

Disclaimer

The opinions expressed in this blog are those of the respective authors. ATB Legal does not endorse these opinions. While we make every effort to ensure the factual accuracy of the information provided in our blogs, inaccuracies may occur due to changes in the legislative landscape or human errors. It is important to note that ATB Legal does not assume any responsibility for actions taken based on the information presented in these blogs. We strongly recommend taking professional advise to ensure the best possible solution for your individual circumstances.

About ATB Legal

ATB Legal is a full-service legal consultancy in the UAE providing services in dispute resolution (DIFC Courts, ADGM Courts, mainland litigation management and Arbitrations), corporate and commercial matters, IP, business set up and UAE taxation. We also have a personal law department providing advice on marriage, divorce and wills & estate planning for expats.

Please feel free to reach out to us at office@atblegal.com for a non-obligatory initial consultation.

Vipul Kulshreshtha

Vipul is a seasoned legal professional with over four years of experience in general corporate practice, mergers and acquisitions, private equity and venture capital fund raise. Vipul is well versed with the regulatory aspects of various sectors such as IT, fintech, healthcare, foreign exchange and financial services.

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