Al Doseri Law, a leading law firm, served as Gold Sponsor of the 2025 Bahrain Business Law Forum, hosted by LexisNexis at the Ritz-Carlton, Manama, marking the firm’s third consecutive year of Gold Sponsorship for this distinguished event.
This year’s forum, themed ‘Law and Policy for a Future-Ready Bahrain’, convened leading legal practitioners, financial experts, and business leaders to examine the kingdom’s dynamic regulatory evolution and its increasing influence in shaping the regional digital economy.
Saad Al Doseri on Stablecoins: Establishing Legal Frameworks for the Future of Financial Trust
As part of the forum’s principal programme, Al Doseri Law founder Saad Al Doseri delivered a comprehensive presentation on stablecoins designed to maintain price stability through various stabilisation mechanisms, examining Bahrain’s pioneering Stablecoin Issuance and Offering (SIO) Module, promulgated by the Central Bank of Bahrain (CBB) in July 2025.
“Stablecoins represent a new form of private money and a major step forward in how we perceive value, trust and currency,” said Mr Al Doseri.
“By integrating the operational efficiency of distributed ledger technology with the stability of fiat-backed reserve assets, stablecoins create a nexus between technological innovation and practical financial utility, enabling enhanced transaction efficiency while maintaining value stability.”
He explained that stablecoins possess significant potential to facilitate cross-border payments, provide value preservation mechanisms in volatile economic environments, and expand financial inclusion in emerging markets. However, their sustainable development is contingent upon maintaining an appropriate balance between technological innovation and prudential regulation, thereby ensuring transparency, consumer protection, and systemic financial stability in accordance with international best practices and Bahrain’s regulatory objectives.
Tracing the market’s development, Mr Al Doseri noted that Tether (USDT), among the first major stablecoins launched in 2014, catalysed an industry that now comprises more than 100 active stablecoins, the majority of which utilise the Ethereum ERC-20 token standard.
“The Central Bank of Bahrain’s SIO Module,” he added, “establishes a comprehensive legal and regulatory framework that anchors this innovation within a structured, transparent and legally robust environment, thereby establishing clear legal rights and obligations for all participants in the stablecoin ecosystem.”
Bahrain’s SIO Module: A Regional First
The SIO Module establishes a comprehensive regulatory framework for fiat-backed stablecoins in the kingdom, encompassing licensing requirements, prudential reserve management standards, redemption rights, ongoing compliance obligations, and regulatory oversight.
Key provisions include:
- Licensing Requirements: Local incorporation as a Bahraini Closed Joint Stock Company (B.S.C. (Closed)) with minimum paid-up capital of BD250,000 and appropriately qualified management personnel possessing the requisite expertise, competence and fitness and propriety standards as defined in the applicable CBB regulations and the SIO Module.
- Full-Reserve Mandate: Issuers must maintain reserves equal to 100 per cent of outstanding stablecoin liabilities in high-quality, highly liquid financial instruments denominated in the reference currency, with such instruments meeting the eligibility criteria specified in the SIO Module.
- Segregation of Assets: Legal and operational separation of reserve assets from the issuer’s proprietary assets, with reserve assets held in segregated accounts and subject to restrictions on encumbrance, to protect stablecoin holders’ interests and ensure priority claims in the event of issuer insolvency.
- Redemption Rights: At-par redemption of stablecoins within five business days from the date of a valid redemption request, including during periods of market stress, subject to compliance with applicable anti-money laundering and counter-terrorist financing requirements.
- Yield Distribution Framework: Permits distribution of yield to stablecoin holders derived exclusively from investment returns on reserve assets, subject to stringent prudential requirements, disclosure obligations, and risk management standards as set forth in the SIO Module and applicable CBB regulations, provided that such distributions do not impair the full-reserve requirement or compromise redemption obligations.
The SIO Module establishes Bahrain as the first jurisdiction within the Gulf Co-operation Council (GCC) to introduce comprehensive, dedicated regulatory provisions specifically governing stablecoin issuance and offering activities, thereby positioning the kingdom at the forefront of digital asset governance in the MENA region.
“Bahrain’s regulatory clarity and legal certainty provide global financial technology firms and digital asset enterprises with a reliable, legally sound gateway into the MENA market,” said Mr Al Doseri.
“The SIO Module demonstrates that technological innovation and market development can flourish within a framework of responsible, principles-based regulatory supervision that balances innovation with investor protection and financial stability.”
Global Regulatory Landscape: Bahrain’s Position Among Leading Jurisdictions
In his presentation, Mr Al Doseri provided a comprehensive comparative analysis of the global stablecoin regulatory landscape as of October 2025, highlighting how Bahrain’s approach distinguishes itself through its regulatory independence, legal clarity, operational adaptability and balanced approach to innovation and prudential supervision.
- European Union: Markets in Crypto-Assets (MiCA) regulatory regime for asset-referenced tokens and electronic money tokens.
- United States: GENIUS Act of 2025 establishing federal regulatory oversight for payment stablecoins.
- Japan: Payment Services Act amendments restricting issuers to licensed financial institutions.
- Singapore: MAS Stablecoin Framework requiring 100pc reserves and five-day redemption.
- Hong Kong: Stablecoins Ordinance mandating full licensing and oversight.
- UAE: Payment Token Services Regulation prohibiting algorithmic designs.
Bahrain’s SIO Module distinguishes itself through its standalone regulatory rulebook, multi-currency flexibility (BD, USD, or other currencies subject to prior CBB approval), and comprehensive redemption and audit provisions, thereby establishing it as a regional benchmark for responsible digital finance.
“Bahrain’s regulatory framework transforms stablecoin issuance from an unregulated market activity into a comprehensively regulated financial service,” noted Mr Al Doseri.
“It establishes a foundation for digital trust, anchored in accountability, transparency, and sound governance principles.”
Legal and Regulatory Excellence: A Vision for a Future-Ready Bahrain
Through the SIO Module, the CBB reinforces its position as a pre-eminent authority in financial technology innovation and regulatory development within the MENA region.
Al Doseri Law, as a leading legal adviser in this domain, continues to provide comprehensive legal counsel and strategic advisory services to domestic and international clients navigating this evolving intersection of law, distributed ledger technology, and financial services, thereby facilitating compliant market entry and operational excellence in Bahrain’s progressive regulatory environment.
Strategic Mergers and Acquisitions: Insights from GLA & Company
Complementing the forum’s focus on future-ready legal frameworks, Asad Ahmad, Partner at GLA & Company, a strategic partner firm of Al Doseri Law, delivered a comprehensive session on the evolving landscape of mergers and acquisitions in the GCC region. His presentation addressed the critical stages of complex corporate transactions, providing attendees with substantive insights into navigating the contemporary dynamic transactional environment.
Mr Ahmad’s session addressed three essential pillars of successful mergers and acquisitions execution.
First, he examined sophisticated transaction structuring and execution strategies, emphasising how regulatory innovation, including Bahrain’s progressive financial technology frameworks, creates enhanced opportunities for cross-border investments and digital asset acquisitions. He highlighted the importance of adaptive structuring mechanisms that can accommodate both traditional business models and emerging technology ventures.
Mr Ahmad then addressed the substantive challenges of transaction completion, focusing on competition law considerations and regulatory approval processes across multiple jurisdictions. He emphasised that successful transaction execution in the MENA region requires comprehensive understanding of evolving legal frameworks governing cross-border transactions, particularly as regulatory authorities in the region continue to enhance their supervisory regimes to facilitate legitimate cross-border commercial activity while maintaining appropriate prudential standards.
Finally, addressing post-merger integration and governance considerations, Mr Ahmad outlined best practices for ensuring long-term transaction success and value realisation. He emphasised the critical importance of robust governance structures capable of adapting to regulatory changes while maintaining operational efficiency and stakeholder confidence – principles that align with Bahrain’s commitment to fostering a stable, transparent, and future-ready business environment conducive to sustainable economic growth.
“The convergence of traditional M&A principles with emerging regulatory frameworks creates unprecedented opportunities for strategic growth,” noted Mr Ahmad.
Al Doseri Law’s Continued Partnership with LexisNexis
As a committed Gold Sponsor of LexisNexis events for the third consecutive year, Al Doseri Law remains dedicated to supporting premier legal forums that advance Bahrain’s evolving legal and regulatory landscape and promote awareness of the kingdom’s progressive regulatory developments. Through its sustained participation in such distinguished events, the firm continues to facilitate meaningful dialogue among legal practitioners, regulatory authorities, and business leaders, thereby contributing to the advancement of legal knowledge and regulatory understanding that supports Bahrain’s position as a leading financial services and technology hub in the MENA region. This partnership reflects Al Doseri Law’s commitment to fostering legal excellence and regulatory innovation that supports the kingdom’s participation in regional and global legal developments.
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