For Firms That Already Hold Stage 1 Approval

VARA Stage 2: Readiness and Implementation

Already have Stage 1 approval? We complete Stage 2 and bring your firm to full operational readiness before VARA reviews it.

Book A Stage 2 Readiness +971 561 365 987

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Service Provider

At this stage, the focus shifts to demonstrating to VARA that the business is fully prepared to operate as a regulated Virtual Asset Service Provider.

Different Engagement
VARA regulatory framework

A Different Question, A Different Engagement

Approval to Incorporate confirms that VARA is prepared to consider an application. It does not confirm that a firm is ready to operate one. The gap between the two is precisely where most Stage 2 engagements stall, and it is the gap this practice exists to close.

Firms reaching this stage typically already have an established legal entity, a defined business model, and an approved regulatory strategy. The challenge lies in implementing the operational framework that underpins the licence, embedding governance into day-to-day operations, establishing a compliance function that is demonstrably effective, and creating a clear evidential trail linking policies, controls, and regulatory obligations. This is where Finjuris provides focused support, helping businesses build the operational architecture required to satisfy VARA's expectations for authorisation.

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Operational Approval

What VARA Expects Before Granting Operational Approval

The following are the areas our practice consistently sees under the closest scrutiny.

01
Governance

Board structure, delegation of authority, and documented decision-making that VARA can trace from policy to practice.

02
Risk Framework

An enterprise risk methodology that identifies, scores, and monitors risk specific to virtual asset activity, not a generic import.

03
Compliance Framework

A functioning compliance monitoring programme, evidenced in operation.

04
Technology Documentation

Architecture diagrams, wallet controls, key management, and cybersecurity policy aligned to the Technology and Information Rulebook.

05
Outsourcing Arrangements

Every third-party dependency identified, documented, and governed by an agreement that satisfies VARA's outsourcing rules.

06
Contracts

Client agreements, vendor agreements, and service-level terms drafted to withstand regulatory scrutiny.

07
Policies

The full suite required under every applicable rulebook, each reflecting how the business operates day to day.

07
Board Documentation

Minutes, resolutions, and approvals evidencing board ownership of the compliance framework.

07
Committee Charters

Terms of reference for every board and management committee.

07
Testing

Evidence that controls have been tested and shall operate in practice.

07
Third-Party Coordination

Custodians, liquidity providers, and technology vendors, aligned and contractually ready before submission.

07
Regulatory Submissions

Every filing and cover communication to VARA prepared to remove ambiguity and demonstrate control of the file.

07
Mock Readiness Reviews

A rehearsal of VARA's own review process, conducted before VARA conducts it.

The Roadmap

The Finjuris Stage 2 Readiness Methodology

Each phase produces a defined output before the next begins.

PHASE 1

READINESS GAP ASSESSMENTWe review the firm's existing policies, governance, and documentation against VARA's Stage 2 expectations for its specific licensed activity, and produce a prioritised gap register.

PHASE 2

BUILD AND REMEDIATION We draft or rebuild every required policy, governance document, committee charter, and contract identified in Phase 1, each tailored to the firm's actual operating model and third- party engagements.

PHASE 3

TESTING AND EVIDENCE COLLECTION We run internal control testing, conduct staff interviews, and assemble the evidence trail VARA expects to see behind every policy statement, so the framework is demonstrably operating and documented.

PHASE 4

MOCK READINESS REVIEW We simulate VARA's own review process internally, testing the firm's governance, personnel, and documentation as a regulator would, and issue a readiness report with any remaining corrective action.

PHASE 5

SUBMISSION AND REGULATOR LIAISON We manage the Stage 2 submission itself and every subsequent exchange with VARA, including Gap List responses, until operational approval is granted.

Service

Who This Service Is For

Firms that hold Stage 1 approval

Firms that hold Stage 1 approval and are preparing their Stage 2 submission for the first time.

Firms already in Stage 2 review

Firms already in Stage 2 review: that have received a Gap List and require focused remediation.

Firms with an existing consultant or in-house team

Firms with an existing consultant or in-house team: that require independent readiness testing before submission, including a mock regulatory review.

For a complete overview of the VARA licensing pathway, including company formation and the decision between a single and combined licence, see our VARA License Dubai guide.

Where a firm already has in-house legal counsel or an existing adviser and requires only build execution across policies, documentation, and third-party coordination, see our VARA Compliance Implementation Services page.

Common Questions

Frequently Asked Questions

Stage 2 is the phase following Approval to Incorporate, during which a firm must build and evidence the full governance, risk, compliance, and technology framework required for VARA to grant operational approval.

Stage 1 tests whether an applicant's proposal is credible in principle. Stage 2 tests whether the firm's actual operational framework satisfies VARA's rulebooks in substance, not only on paper.

A Gap List identifies specific deficiencies in the submission. We prepare and manage every response, and where the gap is substantive rather than clerical, we rebuild the underlying document or control before resubmission.

Yes. We are frequently instructed alongside existing advisers, either to conduct an independent readiness assessment or to take conduct of specific workstreams the existing team lacks capacity to complete.

A structured internal rehearsal of VARA's own review process, testing governance, documentation, and personnel as the regulator would, conducted before the actual submission is made.
Instruct Finjuris

BOOK A STAGE 2 READINESS REVIEW

Our founding principle is straightforward. To deliver world-class legal service to every client we represent, and to become a partner in their success.

A readiness review tells a firm precisely where it stands before VARA does. That is the conversation worth having first.

Book A Stage 2 Readiness Review