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Dubai’s Best Virtual Assets Regulatory Authority (VARA) Consultant

Your Legal and Regulatory Guide from Licensing to Day-to-Day Compliance

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UAE is now one of the heaven for Innovators & UAE without doubt is in the process of regulating Virtual Asset, set an example for the world. If you would like to be a part of the journey then, apply for license under VARA rules & expand your footstep in Virtual Asset like never before. We are here to guide you from Legal & Regulatory Aspect.

“At Finjuris, we endeavor to provide our clients with tailor made legal and regulatory solutions for operating their enterprises dealing with virtual assets while keeping current legislation in mind.”

About VARA

Being the world's first independent virtual asset regulator, VARA functions as a transparent and trusted guiding authority for the burgeoning world of Virtual Assets. VARA intends to take its purpose global by developing a simple framework for regulating the business. VARA assists in minimizing risk and ease cross-border operations and innovation to ensure safe market acceptance and growth by using experience from global experts and organizations and engaging with necessary regional financial regulatory authorities.

Objectives of VARA

VARA License

Positioning Dubai as a regional and worldwide centre for Virtual Assets and associated services, as well as developing a digital economy in the city to increase its competitiveness both locally and globally.

VARA consultant

To inspire investors and raise awareness of Virtual Asset services and products, as well as to inspire innovation in order to generate genuine opportunity.

Virtual Assets Law

To promote the emerging world of virtual assets and to encourage investors and enterprises to establish operations in Dubai.

Legal consultant for VARA

To encourage shared responsibility in crafting efficient and tailored legislation to safeguard investors and to combat illicit practices in collaboration with the relevant institutions.

VARA registration

To create the regulations, norms, and standards necessary for regulating, monitoring, and overseeing Virtual Asset Platforms, Virtual Asset Service Providers, and any other Virtual Asset-related activities.

VARA Dubai License

VARA Licensed Activities

1
Advisory Services

Advisory Services refers to offering, delivering, or agreeing to provide a personal suggestion to a client, either at the client's request or at the Entity making the advice's initiative, with relation to one or more acts or transactions involving any Virtual Asset.

2
Broker- Dealer Services

The term 'Broker-Dealer Services' can apply to any of the following:

  • Arranging orders between two Entities for the purchase and sale of Virtual Assets.
  • Soliciting or accepting orders for Virtual Assets and accepting cash or other Virtual Assets in exchange for such orders.
  • Facilitating the matching of transactions in Virtual Assets between buyers and sellers.
  • Acting as a dealer on behalf of the Entity for its own account in Virtual Assets transactions.
  • Making a market in Virtual Assets using client assets; or
  • Providing placement, distribution, or other issuance related services to clients issuing Virtual Assets.
3
Custody Services

The term 'Custody Services' refers to the safeguarding of Virtual Assets for or on behalf of another Entity and acting exclusively on confirmed orders from/on behalf of such Entity. All VASPs must follow the Rules for the storage and custody of their clients' Virtual Assets. Only VASPs that separate their clients' assets in separate VA Wallets will be eligible for a Custody Services License.

4
Exchange Services

The term 'Exchange Services' can refer to any of the following:

  • Performing an exchange, trade, or conversion of Virtual Assets and currency.
  • Performing an exchange, trade, or conversion of one or more Virtual Assets.
  • Matching orders between buyers and sellers and carrying out an exchange, transaction, or conversion between [i] Virtual Assets and money or [ii] one or more Virtual Assets; or
  • Maintaining an order book in support of items [a], [b], or [c] above.
5
Lending and Borrowing Services

The term 'Lending and Borrowing Services' refers to the execution of a contract under which a Virtual Asset is transferred or lent from one or more parties [the Lender(s)] to one or more other parties [the Borrower(s)], with the Borrower(s) committing to return the same, at the request of the Lender(s), at any time either during or at the end of the period agreed upon, either to its interest or on behalf of others interest.

6
Management and Investment Services

The term 'VA Management and Investment Services' refers to acting as an agent or fiduciary on behalf of an Entity, or otherwise accepting responsibility for the management, administration, or disposal of that Entity's Virtual Assets. Examples include, but are not limited to

  • investment management services or other management of VAs; and
  • Accepting responsibility for the 'staking' of VAs in order to gain fees or other values given to validators and/or node operators of a 'proof-of-stake' DLT.
7
Other Virtual Assets Activities

Before engaging in virtual asset operations in Dubai, any VASP wanting to provide the aforementioned services must apply for and get a license from VARA. Because no virtual asset activity is 'free' from regulatory oversight, any virtual asset service or activity, including but not limited to that provided by DLT service providers, may need a VARA license. Such DLT service providers must assess if they are engaging in any virtual asset activity that falls within the categories listed above.

Proprietary Trading

VA Proprietary Trading will need a VARA no objection certificate to certify that the activity may be carried out with regulatory control without a VA License. Furthermore, proprietary trading above specific trading volumes must be registered with VARA.

VASPs will need to contact their commercial licensors (Free Zones or DET) to submit their Initial Disclosure Questionnaire in order to receive a Propriety Trading NOC.

Activities Related To Virtual Asset Issuance

Before engaging in such action, issuers of Virtual Assets must receive VARA approval of their whitepaper under the "VA Issuance Rulebook."

Why choose us?

Understanding the recently implemented virtual assets regulation in Dubai is not a cakewalk. It needs a lot of understanding and recollection of the laws to prevent any form of regulatory action. We are here to take the pressure off your shoulders.

Finjuris is one of the leading legal organizations in UAE pertaining to fintech, blockchain and cryptocurrency industry. With our presence in various jurisdictions across the globe, we’re well aware of regulations and compliances that one has to keep in mind while running a business. Our team of VARA consultants provide holistic solutions right from legal structuring of your business to licensing.

Our Services Include

Understand the Legal & Regulatory Benefit.
Apply for License
Legally Structure your Company
Legal Risk Audit
Guide you
on Taxation
AML & Data
Protection
Litigation Handling

VARA Authorization is Required for a Variety of Operations, They Include

Platforms for the operation and management of virtual assets
Exchanges services between currencies and virtual assets, whether domestically or internationally
Services exchanged between a form or other virtual asset forms.
Custody, management, and transfer services for virtual assets
Services relating to the portfolio of virtual assets.
Services for providing and exchanging virtual tokens.
VARA Authorization

Residents conducting a business in the virtual assets space without VARA approval are prohibited to continue their operations. We ask you to let us to do what we do best in order to avoid becoming involved in such kinds of situations without specialized knowledge. Since our experts will lead the way, you won't have to second-guess your decision.

Finjuris can assist you with VARA licensing requirements.

Frequently Asked Questions

Being the world's first independent virtual asset regulator, VARA functions as a transparent and trusted guiding authority for the burgeoning world of Virtual Assets. VARA intends to take its purpose globally by developing a simple framework for regulating the business. VARA assists in minimizing risk and ease cross-border operations and innovation to ensure safe market acceptance and growth by using experience from global experts and organizations and engaging with necessary regional financial regulatory authorities.
On 7 February 2023, the Dubai Virtual Asset Regulatory Authority (VARA) issued the Virtual Assets and Related Activities Regulations 2023 (the Regulations), an all-encompassing virtual asset regulatory framework applicable to all Virtual Asset Service Providers (VASPs) in Dubai (excluding the Dubai International Financial Centre (DIFC)). The Regulations provide some much-anticipated regulatory certainty which in turn, should promote protection for investors, sustainable market growth, and stability in the virtual assets sector.
  • Category A: MVP applicants that are currently in the process of securing an MVP Licence
  • Category B: Existing [legacy] Virtual Asset Service Providers [VASP] prior to 07-Feb-2023, that are required to come under VARA supervision
  • Category C: New applicants seeking a VARA Licence or existing applicants adding new activities
  • VA Advisory Services
  • VA Broker-Dealer Services
  • VA Custody Services
  • VA Exchange Services
  • VA Lending and Borrowing Services
  • VA Management and Investment Services
  • VA Payments and Remittances
Exempt Entities includes those entities which have notified VARA and obtained confirmation of its Exempt Entity status in the form of a no-objection confirmation (which may come with certain restrictions or conditions) prior to undertaking any Virtual Asset activities in Dubai. They are not subject to licensing requirements under VARA.
No entity may carry out any Virtual Asset Activity by way of business or promote, offer, or purport to do so, in Dubai, unless it is:
  1. authorised and licensed by VARA for such activity.
  2. an employee carrying on or otherwise facilitating such an activity on behalf of its employer that is licensed by VARA.
You can apply for a VARA Licence through the Department of Economy and Tourism [Mainland] or any Free Zone other than the DIFC. There are two stages of approval:

Stage 1 -Initial Approval - VASPs must complete an Initial Disclosure Questionnaire [IDQ] with DET or a FZA, which will be examined by commercial licensing agencies before being passed to VARA for evaluation.

Stage 2 - Once such requirements have been met, the VASP can apply for Full License Approval [which may contain terms and limits such as access to retail customers].

Market players that have not yet engaged in Virtual Asset Activities, or businesses seeking a commercial or free zone license in Dubai to conduct the following business activities, may voluntarily register with VARA:
  • firms that actively invest their own portfolio in Virtual Assets; or
  • providers of technical services related to or utilizing Distributed Ledger Technology to other enterprises.
Such registration does not authorize or license that entity to engage in Virtual Asset operations in Dubai, nor does it represent any authorization or license from VARA for any commercial operations that entity engages in.
VASPs that are already in the MVP licensing process must confirm with VARA whether they must continue with the MVP process or move to the FMP application, stressing that there will be no duplication of efforts and time for the VASP and that the transfers will be smooth. A gap analysis will be conducted to identify what parts are still outstanding for the VASP to finish the FMP licensing application procedure - the deadline for this application is June 30, 2023.

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