VARA (Dubai): legal support for virtual asset licensing and operations.
- You onboard clients in/through Dubai for virtual asset services.
- You run exchange / broker-dealer / custody / settlement-like flows.
- You have marketing, sales or operations anchored in Dubai.
- Banks/partners ask for a Dubai regulatory position and controls.
- Client types, geographies, onboarding channels.
- Flow of funds/virtual assets, custody responsibilities.
- Revenue model, counterparties and outsourcing map.
- Licensing assumptions and compliance gaps list.
- Governance baseline (roles, reporting, committees if needed).
- Compliance manual and control framework narrative.
- Risk management framework (incl. technology & outsourcing).
- Operational procedures and evidence trail logic.
- CDD/EDD, client risk scoring and review cadence.
- Sanctions/PEP screening workflow and escalation.
- Source of funds/wealth evidence rules.
- STR/SAR escalation logic and recordkeeping baseline.
- Custody responsibility matrix (who holds keys / who can move assets).
- Access management, logging and audit trail baseline.
- Incident response and client communications logic.
- Outsourcing policy + vendor due diligence.
- Client terms / risk disclosures / complaints handling baseline.
- Counterparty agreements (LPs, custodians, vendors, market makers).
- Data/IT clauses, security, service levels, audit rights.
- IP assignment + contractor agreements (for build teams).
- Q&A coordination: evidence, exhibits, internal owners.
- Policy updates after regulator comments.
- Change management: products, flows, counterparties.
- Ongoing legal ops support (post-setup).
- Exchange / trading venue type models.
- Brokerage / dealing / execution (incl. OTC-style flows).
- Custody / safeguarding / wallet management responsibilities.
- Transfer / settlement / payments-like virtual asset flows.
- Issuance / distribution / token offers (model-dependent).
Can we start operations first and apply for VARA later?
That approach often creates avoidable risk: counterparties and banks may ask for a clear regulatory position, and retrofitting controls after launch is usually slower and more expensive. We recommend mapping the model and “licensing trigger points” early.
What do regulators and banks care about first?
Custody/control clarity, AML/KYC + sanctions screening, onboarding and monitoring procedures, governance (roles and escalation), outsourcing oversight, incident handling, and an evidence trail you can actually produce on request.
Is “template documentation” sufficient for a serious VARA route?
Usually no. Templates fail when they don’t match real transaction flows, custody responsibilities, tooling and team roles. We build a document set that reflects your operations and can be implemented by the team.
Do you support ongoing compliance updates after setup?
Yes. Many projects evolve quickly (new products, new markets, new counterparties). We can provide ongoing legal/compliance support to keep documents and controls aligned with reality.
- Exchanges, broker-dealers, OTC desks and trading venues.
- Custody/wallet providers and asset safeguarding models.
- Projects onboarding clients globally with Dubai operations.
- Teams needing implementable AML/KYC + operational procedures.
The goal is simple: a defensible setup that works in real operations and stands up in Q&A.