Dubai 
ParisUsing a UAE Base to Anchor Compute, Export Controls and AI Governance
Can a UAE hub credibly serve as the organizing center for infrastructure, export control and AI risk decisions across an international group?
In the first article in this series, we considered how the UAE is positioning itself as a substantive AI hub, supported by an emerging legal and regulatory framework rather than a purely light touch narrative. In the second, we examined the data protection and cross border data issues that AI businesses encounter when using the UAE as a base, and how those can be managed as part of a coherent governance approach. In this final article, we turn to compute, export controls and AI governance, and consider whether a UAE presence can credibly serve as the organizing center for infrastructure, export control and AI risk decisions across a group.
As AI systems have become more sophisticated, their reliance on high end compute has come into sharper focus. This is the other side of the data picture discussed in the second article and, without access to compute, data strategies cannot be executed in practice. Access to advanced semiconductor chips and specialized cloud infrastructure now underpins many AI business models, and these resources are increasingly subject to export controls and national security constraints in key supplier jurisdictions.
The Meta Manus unwind has highlighted this dynamic by linking concerns around talent and intellectual property relocation with a broader question about where control over compute, and therefore over AI capability, really sits. Chinese authorities framed the decision explicitly in terms of foreign investment, technology export and control over advanced AI capabilities, signaling a willingness to intervene where relocation and integration are seen as vehicles for tech transfer.
Access to compute and infrastructure
In response to these developments, the UAE has invested heavily in digital and data center infrastructure and has taken an active role in international dialogue on AI and emerging technologies. It has sought to position itself as a jurisdiction that offers access to advanced infrastructure, enabling AI businesses to deploy models at scale while maintaining connectivity to leading global cloud providers and semiconductor suppliers.
From a commercial perspective, agreements between UAE based operators and global cloud providers increasingly incorporate provisions addressing export controls, sanctions and data localization requirements. Clauses dealing with change of law risk, licensing, service suspension and termination can have a direct bearing on where workloads may be deployed and which customers can be served from a particular region. Although these provisions are not always labelled as AI specific, they are often central to the practical deployment of AI systems.
Export control considerations and coordination
Many international groups increasingly centralize responsibility for monitoring export control developments and infrastructure dependencies. The UAE has emerged as one of the jurisdictions used for this coordination function, particularly where a group has significant regional operations or is using the Emirates as a base for activity across the Middle East, Africa or South Asia.
From a legal and governance perspective, this role typically involves maintaining a structured internal register of export-controlled technologies and services, tracking applicable licensing regimes for relevant chips and cloud regions and ensuring that supplier contracts are aligned with the group’s risk appetite. Effective coordination also requires clear mechanisms for escalating material developments, such as new or expanded controls on specific technologies or services, to boards and investors in a timely manner.
Where a UAE entity acts as the customer of record for key infrastructure services, it may be particularly well positioned to perform this function. It can negotiate cloud and hardware arrangements, manage supplier relationships and serve as the central point for internal reporting on constraints, dependencies and regulatory change. When implemented properly, this adds a further layer of substance to a UAE hub, so that it becomes a genuine center for infrastructure and export control risk management rather than merely the formal location of contracts.
Evolving expectations on AI governance
Alongside these technical and contractual considerations, expectations around AI governance in the UAE are becoming more clearly defined. Policymakers and commentators have encouraged organizations to adopt internal frameworks grounded in principles such as accountability, transparency, fairness and security, and to assign clear senior level responsibility for AI related risk. In practice, businesses presenting themselves as UAE based are increasingly expected to demonstrate identifiable oversight of key AI systems, supported by documented processes for model development, validation and ongoing monitoring. Policies and contractual arrangements are also expected to reflect accurately how AI systems operate in practice and the safeguards that are in place.
Although the UAE does not yet have a single, comprehensive AI governance code, many of the underlying expectations will be familiar to regulated businesses. These elements can typically be incorporated into existing risk management, compliance, data protection and information security frameworks. By way of example, some organizations have established AI working groups or committees that report into existing risk committees, drawing membership from legal, compliance, technology, data and business functions. Others have introduced formal registers of material AI systems, supported by documented risk assessments.
The UAE as an organizing center
These themes are not unique to the UAE. However, the country’s ambition to position itself at the forefront of AI and the digital economy means they arise frequently in engagement with regulators, major customers and investors. A UAE base can credibly function as an organizing center for AI governance where it has genuine visibility over, and influence on, data, infrastructure and risk‑related decisions.
For founders and investors, a practical way to assess this is to ask three questions.
- Does the UAE entity have clear responsibility for core AI governance functions, including data mapping, model risk management and export control oversight, or are those decisions effectively taken elsewhere.
- Are arrangements with key infrastructure suppliers structured so that the UAE entity can understand, and where necessary negotiate around, constraints that affect group wide operations.
- Are internal governance materials and external statements aligned, such that claims about AI deployment in the UAE are supported by documented analysis and actual practice.
Where the honest answer to these questions is “yes”, or close to it, a UAE hub is more likely to be viewed as a point where AI strategy, legal substance and governance genuinely converge. Where the answer is “not yet”, the Meta Manus story is a reminder that regulators and commentators are alert to gaps between formal structures and where AI activity, infrastructure and control are in fact located.The strategic question for AI businesses is therefore not simply whether to establish themselves in the UAE, but whether they are prepared to use that presence as the true center of gravity for governing their AI operations.
