Enigio BOX 4 Company background: Based in Sweden, Enigio developed its trace:original document-centric solution to facilitate any type of legally verifiable, digitally native documents such as bills of lading and letters of credit. Built to comply with MLETR and other global standards, the company provides scalable solutions for secure document exchange in international trade. Main technology features: –Creation of digital documentation that does not require recipients to use Enigio’s platform –Ability to embed structured data directly into documents –Support for the full document life cycle (amendments, transfers, etc.) –Integration with existing global International Chamber of Commerce (ICC) frameworks (eUCP 600, eURC 522, eURDG) Testing participants: Throughout the sandbox, Enigio worked with the DFSA, the Abu Dhabi Customs Authority, multiple UAE banks (First Abu Dhabi Bank, the National Bank of Fujairah, HSBC Middle East and the National Bank of Bahrain) and logistics providers.Main findings Enigio successfully issued, transferred and enabled recipients to obtain documents without subscribing to the company’s document-centric solution. The technology used structured data directly within documents, allowing for both automation and interoperability with existing systems. Its one-sided adoption capabilities proved particularly valuable, as the tool significantly lowers barriers for counterparties that use different technological systems. The testing demonstrated that documents could be amended, sealed or signed throughout their life cycle, and this capability provided traders with the flexibility they needed to adapt to complex trade transactions. Regulatory takeaways While the testing confirmed that Enigio‘s technology will meet the trade industry’s needs and requirements, it also revealed the limitations of operating within a fragmented legal landscape. The legal enforceability of MLETR-compliant documents remains limited to the ADGM’s jurisdiction, and regulations for cross-jurisdictional transactions are less clear. The sandbox highlighted the need for greater UAE-wide adoption and awareness to ensure legal certainty and consistency across the UAE‘s diverse economic zones. The testing underscored the importance of public–private collaboration in scaling the legal and operational adoption of digital documentation. Coordination among UAE ministries and trade- related agencies emerged as a critical prerequisite for developing consistent implementation guidelines that can bridge the gap between technical capability and regulatory acceptance between financial free-zone regulators such as the DFSA and mainland authorities within the UAE. Advancing Digital Trade: Insights from the UAE TradeTech Regulatory Sandbox 12

Advancing Digital Trade 2025