The regulatory trigger
CBUAE outsourcing rules require the master system of record, including confidential data, to be maintained and stored in the UAE. Sharing confidential data outside the UAE needs Central Bank approval and customer consent mechanics that most "ship the PDF to a cloud LLM" products never survive.
CBUAE guidance on AI and machine learning for licensed institutions stresses governance, accountability, human oversight, data management, and responsibility for third-party AI. The compliance question is not whether the GPU is in Dubai. It is who holds the keys, who runs the weights, and whether the supervisor can still reach the evidence.

