Regulatory strategy

A staged licensing pathway in the United Arab Emirates.

NOVRAIL by SHAKSETTLE is being authorised as an institutional multi-asset settlement rail. The regulatory sequence begins with an ADGM Money Services Business, followed by the Central Bank of the UAE Payment Token Services Regulation, and then a VARA regulated vault and virtual asset custody entity.

Strategic direction

NOVRAILTM is not a money transfer company. It is a regulated institutional multi-asset settlement rail.

The rail is designed to support the transfer and settlement of fiat currencies, payment tokens, stablecoins and fiat referenced tokens, virtual assets, tokenised securities, tokenised commodities, tokenised real estate interests, tokenised funds, institutional collateral and other approved financial and digital assets.

The precise regulated activities depend on the nature of each asset and on whether NOVRAILTM controls, transfers, converts, safeguards, executes or settles that asset. The regulatory perimeter is therefore defined activity by activity, not by a single licence.

Licensing sequence

Three regulators. One coordinated authorisation programme.

01 · Stage one
ADGM Money Services Business
Regulator
Financial Services Regulatory Authority, ADGM
Proposed entity
NOVRAIL Money and Settlement Services Limited
  • Regulated activity of Providing Money Services as the institutional foundation.
  • Institutional money transmission, cross border transfer, foreign exchange and treasury conversion.
  • Fiat leg settlement supporting digital asset and real world asset transactions.
  • The complete settlement rail architecture included in the regulatory business plan from the outset.
  • Additional FSRA permissions sought wherever NOVRAIL deals, arranges, controls, safeguards or settles virtual assets or digital securities.
02 · Stage two
Central Bank Payment Token Services
Regulator
Central Bank of the UAE, PTSR
Proposed entity
NOVRAIL Payment Token and Settlement Services
  • Payment token conversion, transfer and custody under the applicable PTSR category.
  • Registration of approved foreign payment tokens for institutional settlement.
  • Tokenised payment settlement across dirham and foreign payment tokens.
  • Settlement of digital and real world assets using approved payment tokens.
03 · Stage three
Vault and Virtual Asset Custody
Regulator
Virtual Assets Regulatory Authority, Dubai
Proposed entity
NOVRAIL Vault Custody FZE
  • Institutional virtual asset custody with wallet segregation and key management.
  • Settlement custody, asset locking and conditional release.
  • Collateral custody where authorised.
  • Safeguarded digital asset storage completing end to end delivery versus payment.

Preparatory work on the Payment Token Services and VARA applications may proceed in parallel once the ADGM operating model and regulatory perimeter have been defined.

Settlement models

From routing only to full multi-asset settlement.

Model A
Technology only routing

Messaging, connectivity, route recommendation, reconciliation and settlement status monitoring. No money held, no assets held, no key control.

Model B
Regulated money leg settlement

The ADGM MSB permission receives and transmits permitted money, performs foreign exchange and settles the cash leg while the asset leg is coordinated through an external custodian or venue.

Model C
Digital asset settlement coordination

Money leg settlement combined with digital asset instruction routing, integration with regulated custodians and confirmation of completion across both legs.

Model D
Full multi-asset settlement

Control or execution of both settlement legs across money, payment tokens and approved digital assets, with integrated custody and delivery versus payment. The longer term regulated objective.

Model E
Tokenised RWA settlement

Issuer, registrar, bank, custodian and investor connected in a single coordinated transfer of the tokenised asset against the payment obligation, with legal and ledger settlement confirmed.

The phased model connects licensed banks, custodians, regulated exchanges, broker dealers, payment token issuers, settlement banks, tokenisation platforms and central securities depositories. Designated institutions hold the underlying money or assets until NOVRAILTM obtains all necessary custody and asset control permissions.

Regulatory perimeter

Each activity mapped to its own permission.

Where NOVRAILTM only transmits messages or provides software, the activity remains technological. Where it receives client money, executes transfers, converts assets, controls wallets or effects legal settlement, regulated permission is required.

Money services
Providing Money Services, FSRA
Institutional transmission, conversion and fiat settlement.
Technology and messaging
Generally unregulated
Message transport, routing logic and reconciliation software where no value is controlled.
Virtual assets
Additional FSRA permissions
Receiving, transmitting, converting or controlling virtual assets.
Digital securities and tokenised investments
Capital markets permissions
Tokens representing shares, bonds, sukuk, fund units or derivatives.
Payment tokens
CBUAE jurisdiction
Fiat referenced tokens used as a means of payment.
Custody and client assets
FSRA and VARA
Safeguarding money or digital assets on behalf of institutions.
Corporate structure

Legally segregated entities, one settlement network.

NOVRAIL Money and Settlement Services Limited
ADGM, FSRA

Money services, fiat settlement, foreign exchange, settlement coordination.

NOVRAIL Payment Token and Settlement Services
Central Bank of the UAE

Payment token issuance where approved, conversion, custody, transfer and tokenised settlement.

NOVRAIL Vault Custody FZE
Dubai, VARA

Institutional virtual asset custody, key management, settlement custody and asset release.

SHAKSETTLE Technology and Intellectual Property
Group company

Ownership of NOVRAIL intellectual property, network architecture, messaging, ISO 20022 mapping, routing and software.

NOVRAILTM is the regulated institutional settlement rail developed and powered by SHAKSETTLETM, which remains the founding group, strategic parent, technology originator, intellectual property owner and principal shareholder.

Engage

Discuss the regulatory model with us.

We brief regulators, counsel, institutions and partners on the authorisation pathway, the settlement models and the perimeter that governs each activity.