For In-house Legal Teams And Licensing Advisers

VARA Compliance Implementation Services

Beyond advice. We build, coordinate, and implement the operational framework VARA requires for regulatory approval.

Instruct Implementation Team +971 561 365 987

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guide clients

Advice tells a firm what VARA requires. Implementation is what comply with VARA. This service exists for firms that already know what they need. What they are missing is the team to build it.

Implementation

An Implementation Partner, Not a Second Opinion

Many of the firms instructing us on this basis already have in-house legal counsel, an existing licensing adviser, or a compliance consultant engaged. Our role is to complement them by delivering the implementation work that bridges regulatory strategy and operational readiness.

We integrate seamlessly with existing project teams, taking responsibility for drafting policies, developing governance frameworks, coordinating third-party vendors, preparing supporting documentation, and building the evidential framework that demonstrates compliance with VARA's requirements. We provide the implementation capability that enables the wider project to move forward with confidence.

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The Detail

Policy Drafting

The documentary core VARA reviews line by line. Each policy is drafted to reflect the instructing firm's actual operating model, not adapted from a template library.

AML/CFT

Policy and procedures aligned to VARA's rules and the UAE's National Risk Assessment methodology.

Governance

Corporate governance framework, delegation of authority, and decision-making protocols.

Risk

Enterprise risk management framework calibrated to the firm's specific licensed activity.

Technology

Information security architecture, key management, and wallet control documentation.

Cybersecurity

Policy and incident response procedures aligned to the Technology and Information Rulebook.

Outsourcing

policy governing the assessment, contracting, and ongoing oversight of third-party providers.

Incident Reporting

Internal escalation and external notification procedures for operational and security incidents.

Complaints

Client complaints handling procedure, aligned to Market Conduct requirements.

Market Conduct

Marketing, disclosure, and client communication standards.

Conflicts

Conflicts of interest policy covering personal, corporate, and client-facing scenarios.

Internal Controls

Control documentation mapped to each risk identified in the firm's risk register.

Documentation

Business Documentation

The narrative and financial substantiation behind the policy suite, prepared to the standard VARA expects to see supported by evidence.

Business Plan

The Regulatory Business Plan, tailored to the firm's licensed activity or activities.

Financial Model

The Regulatory Financial Plan, including capital adequacy calculations specific to each licensed activity.

Compliance Monitoring Programme

A documented testing calendar evidencing that controls are checked, not merely designed.

Risk Register

A live register of identified risks, ownership, mitigation, and residual exposure.

Product Risk Assessment

Assessment of each virtual asset product or service line against applicable regulatory risk.

Client Journey

Documented onboarding, due diligence, and ongoing monitoring workflow from a client's first contact onward.

Internal Procedures

Operating procedures translating each policy into day-to-day staff instruction.

VARA expects

Governance

The structures VARA expects to see functioning, not merely constituted on paper.

Board Committees

Structure and mandate for each committee required by the firm's governance framework.

Terms of Reference

Charters defining membership, authority, and reporting line for every committee.

Compliance Function

Structure, independence, and reporting line of the compliance function itself.

MLRO

Role definition, authority, and escalation pathway for the Money Laundering Reporting Officer.

Risk Officer

Role definition and reporting line for the individual accountable for the risk framework.

Internal Reporting

Management information and board reporting packs evidencing genuine oversight.

Relationships and Contracts

Third-Party Coordination

This is the discipline most licensing advisers do not resource, and it is frequently the reason a otherwise complete Stage 2 file stalls. A policy suite is only as credible as the vendor relationships and contracts standing behind it, and VARA reviews both together.

01
Custodian coordination

Aligning custody arrangements and reserve evidencing with VARA's requirements.

02
Banking

Coordination with UAE banking relationships to support the firm's operational and client-facing needs.

03
Liquidity providers

Contractual and operational alignment for firms undertaking exchange or broker-dealer activity.

04
Blockchain analytics

Coordination with on-chain monitoring providers supporting AML transaction surveillance.

05
Travel Rule providers

Integration of Travel Rule compliance solutions into onboarding and transaction workflows. .

06
KYC/KYB vendors

Coordination of identity verification and due diligence tooling with internal procedures.

07
Technology vendors

Documentation and contractual review for order management, portfolio, and core banking systems.

07
Insurance

Coordination of coverage appropriate to the firm's licensed activity and risk profile.

07
External auditors

Engagement coordination for financial and reserve audits required under VARA's rules.

07
Penetration testing

Coordination of independent security testing to evidence the technology framework's resilience.

07
Legal opinions

Sourcing and review of third-party legal opinions where VARA or a counterparty requires one.

final layer

Operational Readiness

The final layer, converting a completed document set into a framework that functions under regulatory review.

Gap analysis

structured comparison of current state against VARA's Stage 2 expectations.

Evidence collection

Assembly of the documentary trail behind every control and policy statement.

Internal testing

Verification that controls operate as designed, not only as documented.

Staff interviews

Preparation of Responsible Individuals and key staff for regulatory questioning.

Training

Role-specific instruction so staff can explain, not merely follow, the framework in place.

Regulatory walkthroughs

Rehearsed walkthroughs of the firm's operating model as VARA would test it.

final layer

One Methodology, Multiple Regulatory Regimes

The methodology outlined in this service, reflects a regulatory implementation approach applicable across multiple licensing regimes. While each jurisdiction applies its own regulatory requirements, the underlying regulatory principle remains consistent.

The implementation framework remains consistent; however, each deliverable is independently mapped against the specific legal and regulatory requirements applicable to the relevant jurisdiction.

Where a business has not yet commenced the VARA licensing process and requires support across the complete licensing lifecycle, including entity structuring, incorporation, regulatory submission, and operational readiness, please refer to our VARA License Dubai guide

Where a business has progressed through the initial approval stage and requires assistance implementing the governance, compliance, operational, and evidentiary framework required for regulatory approval, please refer to our VARA Stage 2 Readiness and Implementation service.

Common Questions

Frequently Asked Questions

No. We are typically instructed alongside existing counsel, taking conduct of drafting, coordination, and evidentiary build while the instructing firm retains ownership of strategy and the regulatory relationship.

Yes. Instructions can be scoped to a single workstream, a full policy suite, or the complete implementation programme described on this page.

Yes. Third-party coordination is a core part of this service, including custodians, banking relationships, liquidity providers, and technology vendors.

No. The underlying methodology is jurisdiction-agnostic and has been applied across other regimes, including ADGM, DIFC, FSCA, MiCA, MAS, and Hong Kong, with only the rulebook mapping changing.

Once scope is agreed, workstreams typically begin within days, run in parallel rather than sequentially, and are reported against a defined delivery timetable.
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Ready to Build Your VARA Framework?

Your team understands the regulatory requirements. We provide the implementation capability to turn those requirements into an operational framework ready for VARA review.

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