Jurisdiction • UAE • VARA (Dubai)
VARA (Dubai): legal support for virtual asset licensing and operations.
VARA is Dubai’s dedicated virtual asset regulator. If your business touches exchange/brokerage, custody, issuance or other virtual asset activities
in Dubai, you typically need a clear licensing route, a robust compliance framework, and a set of operational documents that match real flows.
We focus on “implementation-ready” governance, AML/KYC, risk and operational procedures — not generic templates.
When VARA matters most
- 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.
Also see UAE overview: UAE.
Scope
What we do for VARA projects
We cover the legal layer end-to-end: model analysis → licensing scope → compliance & governance → contracts and policies → regulator Q&A support.
Step 1
Activity mapping & route memo
A practical “what triggers what” analysis based on your real product and flows.
- Client types, geographies, onboarding channels.
- Flow of funds/virtual assets, custody responsibilities.
- Revenue model, counterparties and outsourcing map.
- Licensing assumptions and compliance gaps list.
Output: a clear decision memo and scope for next steps.
Step 2
Licensing documentation set
A structured pack aligned to the business model and internal controls.
- 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.
Designed to be defensible in regulator Q&A.
Step 3
AML/KYC & sanctions controls
Risk-based onboarding, ongoing monitoring and escalation rules.
- 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.
Critical for banking and counterparties.
Ops
Custody / safeguarding & tech controls
Controls for wallets, key management, access, incidents and vendor oversight.
- 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.
Designed around real infrastructure, not generic words.
Legal
Contracts & client-facing docs
Legal docs that match your regulated position and operational model.
- 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).
Often required before onboarding partners at scale.
Support
Regulator Q&A and ongoing updates
Structured responses and document updates as the project evolves.
- Q&A coordination: evidence, exhibits, internal owners.
- Policy updates after regulator comments.
- Change management: products, flows, counterparties.
- Ongoing legal ops support (post-setup).
Goal: keep the compliance layer aligned with reality.
Positioning
Typical VARA activity buckets (high level)
Exact classification depends on how your product works (especially custody responsibility, execution model and client interface).
We start with an activity map before naming the route.
Activities that often trigger licensing
- 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).
The key: what is promised to clients, who controls private keys, and how orders/settlement are executed.
What we confirm early (to avoid surprises)
Custody & control
Who holds keys? Who can move assets? What is the approval workflow?
Client type & geography
Retail vs professional, markets served, marketing channels and restrictions.
Fiat rails & counterparties
Banks/PSPs, on/off ramps, liquidity providers, custodians, vendors.
Outsourcing map
Who runs what: tech stack, KYC, custody, trading, support, security.
Related: Compliance and
Web & Crypto.
FAQ
Common questions about VARA
Short answers. We always start from your actual flows and compliance capability before finalizing a route.
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.
Need a VARA-ready legal & compliance scope?
Send a short description: what you do, whether you hold client assets, target markets, and your planned counterparties (banks/PSPs/custodians).
We’ll propose a concrete route memo and the first deliverables.
If you already have policies and procedures, we can start with a gap analysis and rebuild only what is missing.
Good fit for VARA support:
- 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.