Crypto Projects at TOKEN2049 Dubai: Navigating UAE Marketing Rules – What You Should Know

Disclaimer: This article is for informational purposes only and does not constitute legal advice. It is intended for foreign crypto projects attending Token2049 Dubai and does not replace professional legal counsel. Please consult a qualified UAE lawyer for case-specific advice.

Dubai has become a global magnet for virtual asset innovation, but it is also one of the most comprehensively developed and well-regulated crypto jurisdictions in the world. If you're planning to attend Token2049 and your crypto project is not licensed by the Dubai Virtual Assets Regulatory Authority (VARA) or the UAE's Securities and Commodities Authority (SCA), you must understand what constitutes legal crypto marketing activity under UAE law.

This articles is a practical guide for foreign projects visiting Dubai’s leading Web3 conference.

What Crypto Marketing is Regulated in Dubai? VASPs & Non-Regulated Crypto Projects

First of all, while there are two key categories of attendees coming to Dubai for Token2049 from outside the UAE that should comply with the requirements of the VARA’s Marketing Regulations (the “Regulation”):

1. Virtual Asset Service Providers (VASPs): These entities engage in services such as exchange, custody, advisory, or brokerage. Their activities are considered regulated and require a license to operate or market within Dubai. Marketing of any VASP activity must only be conducted by a provider that is either licensed or acting under the authority of a licensed provider.
2. Non-Regulated Web3 Projects: These are often protocol teams or DAOs based outside the UAE that may not provide regulated services but nonetheless offer their tokens or intend to build awareness around them.Even where such protocols or DAOs are not financial service providers, offering or promoting a token still constitutes marketing a Virtual Asset and, as such, falls within the scope of the Regulation.

It does not apply to technical infrastructure builders, protocol developers, or other Web3 projects that do not offer tokens, do not solicit investment or signups, and are not conducting any VASP Activity, as defined by VARA, for example non-custodial tools and protocols, developer libraries, or research-focused projects. These non-relevant entities are not subject to the Dubai crypto event compliance requirements and marketing restrictions covered in this article. In other words, if you are not a Relevant Project, the Regulation and marketing restrictions generally do not apply to your participation in a UAE blockchain conference.

During Token2049 in Dubai

Inside the Conference: What You Can Do

Relevant Projects without UAE license or authorization are permitted to engage in limited marketing within the conference venue. This includes showcasing technology, displaying the brand, and explaining the functionality of the service or product. Name and logo displays as well as informational demonstrations are allowed.

Participation in panels must be strictly informative in nature. Speakers may explain features or provide information about a product or service but must refrain from making any recommendations regarding any product, service, or virtual asset.

Regulation:

"Entities that are not Licensed by VARA may carry out Marketing of or relating to Virtual Assets or VA Activity at physical events held in the Emirate, provided that... such Marketing consists only of the following: the name of the Entity; a logo...; a reference to the types of activities...; and information for the purposes of explaining the product and/or service, or for educational purposes only."

Participation in panels is permitted but must be strictly informative in nature. Speakers may share thought leadership, technical insight, and provide information about a product or service, including its features. However, they should avoid promotional language, making recommendations, or inviting attendees to invest, sign up, or take any action related to a specific product, service, or virtual asset.

Regulation:

"Participation in panel discussions and presentations would not be in breach... however the discussions should focus only on providing informative content and knowledge... must not make any recommendations with respect to any product or service or Virtual Asset."

Speakers and projects are advised to avoid onboarding UAE residents as clients, soliciting investments, or conducting token sales. Booth staff must ensure that UAE residents are not permitted to sign up or undergo onboarding. Any form of solicitation or lead generation targeting local participants may be deemed a regulatory violation.

According to VARA all marketing materials must include a prominent disclaimer stating that the project is not licensed or regulated by VARA and is therefore not permitted to conduct Virtual Asset Activities in the Emirate of Dubai.

Exhibitors should avoid promoting investment returns or distributing any promotional material that could be interpreted as incentivizing token acquisition. Giveaways such as branded merchandise are permitted, provided they do not serve as marketing triggers. Workshops and panel appearances must be educational. Speakers may describe their platforms but must not recommend purchases or encourage investment behavior.

VARA also allows an exemption for purely personal or private communications, which are not considered marketing. However, this exemption is tightly limited – any communication accessible to 50 or more people, even in a private Telegram group or niche Twitter post, may be considered public and still be classified as marketing. VARA retains full discretion in determining what qualifies as “purely personal or private,” underscoring the narrow and subjective nature of this exception.

Outside the Conference: What You Cannot Do

Outside the conference venue, the rules tighten dramatically. Side events, PR campaigns, influencer marketing, and any ad placement targeting by Relevant Projects the UAE are likely to be in breach if conducted without VARA approval.

Marketing is deemed to target the UAE if the promotional materials include:

• Local press or influencers;
• Dubai imagery;
• AED pricing or Dubai visuals;
• Targeted digital ads or public event activations.

Regulation:

"VARA deems any Marketing that targets the UAE to, by default, be targeting Dubai." “Campaigns targeting member states of the Gulf Corporation Council [GCC] as a whole will by default be deemed to include the UAE.”

VARA defines marketing activity broadly – it includes any advertisement, invitation, inducement, solicitation, offer or promotion, encompassing both direct and indirect promotion: > “VARA will take all relevant circumstances into consideration when assessing whether a communication or activity qualifies as Marketing, including... the target audience, how the communication is publicised, and whether there is a commercial purpose.” — VARA Marketing Guidance 2024

Relevant Projects are advised to geo-block UAE access to campaign sites and clearly include disclaimers that services or tokens are not offered in the UAE.

Relevant Projects are advised to avoid distributing flyers, NFTs, or marketing material beyond the venue. Even handing out QR codes linking to wallets or minting platforms may be interpreted by regulators as marketing activity in breach of UAE rules.

Social Media Campaigns Around Token2049

Many crypto teams are trying to create PR and hype around their presence at Token2049. This includes organic posts, paid ads, and even influencer shoutouts. However, where your project is a Relevant Project, you are strongly advised to ensure that any marketing or promotional activity does not directly or indirectly target UAE residents.

As discussed above, your crypto marketing is deemed to target the UAE residents if the promotional materials include local press or influencers, Dubai imagery, AED pricing or Dubai visuals, targeted digital ads or public event activations.

KOLs and Influencers at Token2049: Special Duties

Key Opinion Leaders (KOLs) and influencers are a core part of any Web3 marketing – but their obligations under UAE law are rather strict. Accroding to VARA each promotional post by an influencer relating to a Relevant Project must include a clear disclosure in the caption indicating that the content is an advertisement or paid promotion, for example: 'Sponsored by…' or 'In paid partnership with...' in a prominent place.

KOLs are encouraged to verify whether a Relevant Project they promote is VARA-authorized and are responsible for ensuring that each piece of content contains the appropriate disclosures. Furthermore, if the Relevant Project that a KOL is promoting is itself not authorized or licensed to market tokens or offer services in the UAE, the KOL is also prohibited from marketing on its behalf within the UAE or targeting the UAE residents. This includes promoting unlicensed token offerings or services to UAE residents by way of posts, partnerships, or event appearances.

Thus, KOLs are subject to all the same, or even stricter, limitations that apply to the Relevant Projects they promote, including restrictions on targeting UAE audiences, mandatory disclaimers, diligence checks, and more.

Who Needs to Be Aware?

To avoid potential violations and ensure compliance, it is important that the following actors are aware, fully understand and know how to comply with the requirements for crypto promotion in Dubai and UAE:

• A Web3 project offering tokens in any form;
• A VASP (licensed or not) conducting or promoting virtual asset services;
• Marketing companies, PR agencies and other firms representing crypto clients;
• Influencers, celebrities and ‘ambassadors’ working with crypto sponsors.

While Dubai is crypto-friendly, it remains compliance-intensive. Understanding and respecting the rules is essential. Let your presence reflect regulatory awareness and long-term credibility.

So please go ahead and share this guideline with anyone who is heading to Token2049 Dubai to pitch or build awareness about their projects.

If your crypto project is preparing for Token2049, now is the time to review your marketing strategy and localize it in line with VARA’s 2024 marketing guidance and Regulation.