Regulating online gold markets in Persian Gulf: A comparative analysis for Iran
By Golzar Aghaei
Economic policy specialist
Iran’s online gold market—an increasingly systemically relevant segment of the country’s retail savings and investment architecture—remains trapped in a regulatory no-man’s-land between the Central Bank of Iran (CBI) and the Deregulation Board. The executive directive issued in Aban 1404 (October–November 2025) obliges the CBI to operationalize a supervisory infrastructure within three months, yet unresolved jurisdictional questions continue to impede the formation of a coherent regulatory perimeter. This institutional vacuum is not merely an administrative nuisance: it distorts price discovery, elevates counterparty and custody risk, and creates fertile ground for regulatory arbitrage. Against this backdrop, the regulatory trajectories of Iran’s southern neighbors in the Gulf Cooperation Council (GCC) offer a comparative laboratory—not of ready-made models, but of sequenced, risk-calibrated approaches to governing an asset class that sits at the intersection of commodities, digital finance, and retail speculation. A comparative analysis of these experiences—without overstating their effectiveness—can inform Iran’s policy choices as it seeks to move from regulatory limbo to a predictable, enforceable framework.
UAE: Pilot programs
Contrary to conventional wisdom, the UAE has not yet adopted a dedicated framework for gold tokenization. On 8 October 2025, the Dubai Multi Commodities Centre (DMCC) and the Virtual Assets Regulatory Authority (VARA) announced a joint pilot program to assess the tokenization of gold and diamonds. The pilot evaluates “technical and regulatory requirements, market viability, and investor protection” and has not yet reached the stage of final rulemaking. During this period, the issuance of backed tokens operates under VARA’s existing framework for “Asset-Referenced Virtual Assets” (ARVA), which requires monthly disclosure of reserve holdings and independent audits every six months. The “UAE model” is therefore a phased, pilot-based approach, not a proven operational framework.
Bahrain: Approved framework with structural limitations
Unlike the UAE, Bahrain has an operational framework. On 3 February 2025, the Central Bank of Bahrain (CBB) approved the “Gold Bar Token” whitepaper for the ATME exchange. Each token represents one kilogram of gold held in custody and is offered exclusively to accredited investors. However, the CBB’s approval is explicitly limited: the central bank “will not exercise ongoing supervision over the token issuer or its project after issuance” and “has not approved the associated smart contracts.” This structural limitation demonstrates that even approved frameworks can contain supervisory gaps.
Saudi Arabia: Legislation at draft stage
In August 2025, Saudi Arabia published the draft “Executive Regulations for the Precious Metals and Gemstones Law” for public consultation. The draft permits online sales of precious metals “subject to requirements determined by the Ministry of Commerce.” However, the document remains in draft form and its final approval is uncertain. Citing the “Saudi experience” at this stage means citing a proposal, not an implemented practice.
Qatar: From prohibition to new framework
Until December 2019, Qatar prohibited virtual asset services in the Qatar Financial Centre. In September 2024, however, it introduced a “Digital Assets Framework” that defines “permitted” tokens as “digital representations linked to approved rights” while excluding cryptocurrencies as “excluded tokens.” Tokenizing gold under this framework is possible through a three-stage process: “validation, tokenization application, and token generation.” Nevertheless, the framework is very new, and no specific operational product has yet been launched under it.
Kuwait: A Payment-Channel Approach Rather Than Platform Supervision
Rather than regulating online gold platforms, Kuwait has focused on controlling payment channels. Ministerial Decision No. 182/2025 prohibits all cash transactions in the precious metals trade and restricts payments exclusively to “non-cash methods approved by the Central Bank of Kuwait.” This approach controls money flows rather than supervising platforms, representing a substantively different model from other regional states.
Conclusion and Implications for Iran
A close examination of Persian Gulf experience reveals that there is no single “model” for regulating online gold markets: the UAE is at the pilot stage, Bahrain has a limited framework, Saudi Arabia is at the draft stage, Qatar has just emerged from prohibition, and Kuwait has chosen a payment-control path. Consequently, recommending “emulation” of any one of these experiences without considering its stage of evolution would be misleading.
The practical implication for Iran is that, rather than searching for a “best model,” it should pursue a “phased learning process.” The CBI’s supervisory system, currently undergoing final security testing, could serve as the technical infrastructure for a controlled pilot—similar to the UAE approach. Publishing pilot data (trading volume, physical reserve ratios, settlement times) before finalizing regulations would align with regional experience and reduce the risk of adopting a framework that proves ineffective in practice.