Legal Memorandum: eSIM Offering Regulatory Implications

Project: UAE Regulatory Assessment – Riyadh Air eSIM Offering

I am looking for an experienced legal/regulatory drafter to assist with preparing a polished, client-ready memorandum assessing the UAE regulatory implications of a proposed eSIM offering by an international airline.

I have already prepared the factual background, gathered regulatory feedback from the relevant authorities, identified the applicable legal framework, and outlined the structure of the memorandum. I am therefore not looking for primary research from scratch, but rather for assistance in converting the materials into a comprehensive, well-reasoned final memorandum that addresses the relevant regulatory considerations and reaches clear conclusions.

The memorandum should cover, amongst other things:

• Background and overview of the proposed business model;
• Analysis of two proposed structures:

eSIMs provided as part of flight fare bundles; and
eSIMs offered through a dedicated/white-label website;
• UAE telecommunications and licensing considerations;
• Consumer protection considerations;
• Data protection considerations;
• E-commerce and electronic transactions considerations;
• Assessment of informal guidance received from relevant UAE authorities;
• Regulatory risks associated with each model;
• Practical risk mitigation measures; and
• Final conclusions and recommendations.

The applicable legal framework has already been identified and includes UAE telecommunications regulations, consumer protection laws, data protection legislation, e-commerce regulations and related regulatory guidance.

I will provide:
• Detailed factual background;

• Preliminary legal analysis; and
• Proposed memorandum structure.

The deliverable should be a professionally drafted, client-facing legal memorandum in final form, with clear reasoning, concise analysis, practical recommendations and a definitive conclusion addressing the client's key questions.

Experience drafting regulatory, telecommunications, technology, data protection or commercial advisory memoranda for law firms or professional services firms would be highly advantageous.