For exchanges, brokers, custodians, OTC desks, and crypto payment teams, Dubai’s Virtual Assets Regulatory Authority (VARA) has become a credible way to operate under a supervisor that understands digital assets. The draw isn’t marketing; it’s a rulebook that partners can validate and a jurisdiction where talent, capital, and service providers already “speak crypto.”
If you’re weighing options, read this as a practical brief—when VARA fits, what to prepare, and how to avoid the classic slowdowns.
Why Dubai (and why now)
-
Clarity with momentum. VARA gives dedicated coverage to virtual assets rather than squeezing them into legacy categories.
-
Partner perception. Banks, PSPs, insurers, and enterprise procurement teams increasingly expect a regulated counterparty for higher-value contracts.
-
Operating density. Access to local legal, compliance, payments, and infrastructure vendors who have lived through crypto use cases.
None of this makes VARA “easy.” It’s a compliance-first environment. The advantage goes to teams that can prove controls—not teams that can promise them.
Who typically benefits
-
Spot exchanges / broker-dealers needing supervised status to unlock payment rails and institutional listings.
-
Custodians serving funds and treasuries that require trust layers around key management and ops.
-
OTC and market makers formalizing governance, surveillance, and reporting.
-
Cross-border payments/remittance players building corridors that depend on predictable oversight.
If your roadmap is purely experimental or privacy-max with no partner dependencies, VARA probably isn’t the right fit. If your pipeline lives or dies on bank, PSP, or enterprise trust—it might be.
The one thing that actually moves approvals: evidence
Partners (and regulators) buy evidence:
-
Accountable people. A Compliance Officer and MLRO with real authority; fit-and-proper profiles that match the activities.
-
Operationalized policies. KYC/KYB, sanctions screening, transaction monitoring, outsourcing, incident response—configured, tested, and logged.
-
Governance with minutes. Short, real records showing decisions, challenges, and follow-through.
-
Vendor files. SLAs, security notes, performance checks for KYC tools, analytics, custody, cloud, and PSPs.
-
Training and access. Registers for role-specific training; access-control proofs and change logs.
Think in screenshots, logs, and registers—not just beautifully formatted PDFs.
What to prepare before you apply
1) Entity & structure
-
Incorporate a Dubai entity suited to your chosen activity.
-
Map your business model to VARA categories (exchange, broker, custodian, advisory, etc.). Be explicit about what you won’t do.
2) People
-
Appoint experienced managers for regulated roles (no “on paper” titles).
-
Ensure decision rights are documented and visible in governance.
3) Systems & documentation
-
Policies → controls. Draft, tailor, configure, test. Keep artifacts (test results, sample alerts, playbooks).
-
Risk framework. Enterprise risk assessment and product/use-case scoring that ties to monitoring rules.
-
Financial plan. Realistic P&L, capital runway, and wind-down plan that matches your scale-up story.
Application path (high level)
-
Pre-application scoping. Map services to categories; identify gaps in people, capital, or controls.
-
Entity setup & resourcing. Incorporate, confirm directors and key persons, lock in service providers (audit, compliance support, legal, and tech).
-
Policy & control build-out. Configure screening/monitoring, evidence change management, and incident handling.
-
Submission. Provide a complete pack—forms, ownership/control, CVs, policies, risk assessment, business plan, financials.
-
Dialogue. Expect queries; answer with documents and records, not intentions.
-
Grant & go-live. Operate exactly as licensed; maintain registers and manage changes through notifications/approvals.
For scope, documents, and timelines, start with the overview of the Dubai VARA license.
Operating obligations to budget for
-
AML/CFT routines. CDD/EDD, PEP/sanctions screening, refresh cycles, STR/SAR processes.
-
Monitoring & casework. Rules, alert triage, escalation, and audit trails.
-
Reporting cadence. Regulatory returns, incident reporting, and material-change notices.
-
Training. Role-based onboarding, annual refreshers, and drills for incidents.
-
Operational resilience. Business continuity, disaster recovery, vendor risk management, and post-incident reviews.
Treat these as product features of a licensed firm. They’re what partners actually pay for.
Strategy: when VARA vs. alternatives
-
Dubai (VARA). Strong brand and partner acceptance across MENA/APAC; higher substance and cost than offshore.
-
EU (MiCA). Heavier lift but passporting and enterprise procurement upside if the EU is core to your go-to-market.
-
Offshore hubs (e.g., Seychelles/BVI). Useful for speed and cost; partner comfort depends on your governance and evidence.
Avoid the slowdowns
-
Template soup. If policies don’t match your stack, reviewers will stall.
-
Under-resourcing compliance. A part-time MLRO with no tooling is a red flag.
-
Unclear product boundaries. Publish a one-pager that states what you do, what you don’t, assets covered, and blocked geos.
-
Single-rail payments. Always maintain a backup payments rail.
“With global crypto adoption reaching new heights in 2025, many businesses are seeking VASP licenses across diverse jurisdictions – from established offshore centers to forward-thinking regulatory regimes,” said Aaron Glauberman, CEO of LegalBison. “We focus on providing clear, practical guidance so entrepreneurs can expand with certainty.” LegalBison has built its reputation as a specialist in company formation and crypto licensing worldwide.
Disclaimer
This article is for information only and does not constitute legal, tax, or investment advice. Requirements evolve; validate details against current supervisory materials and professional advice before acting.