Introduction to VARA Virtual Asset License

Dubai has rapidly emerged in the Middle East with its innovative technology ecosystem and forward-looking policies, becoming one of the global centers for cryptocurrency and blockchain technology. With its open business environment, multicultural background and pro-business policies, Dubai has attracted the attention of many Web3 companies and startups. As one of the most important emirates in the UAE, Dubai has developed from a small fishing village into a center of international finance and business, and is now fully transforming into a hub for the cryptocurrency and blockchain industries.

In 2021, the Dubai Multi Commodities Centre (DMCC) launched the Crypto Center, providing incubation, financial support and other services to cryptocurrency entrepreneurs to help projects be implemented quickly. Subsequently, the Dubai Virtual Asset Regulatory Authority (VARA), established in 2022, provided a world-leading regulatory framework for the industry, making Dubai a preferred location for cryptocurrency exchanges and other virtual asset businesses to establish regional headquarters. Industry giants including Binance and Bybit have established regional headquarters in Dubai, further strengthening Dubai's position as a global crypto hub.

The Dubai Virtual Asset Regulatory Authority (VARA) was established in 2022. The driving force behind it is the Dubai government's desire to promote the healthy development of virtual assets and blockchain technology through a clear regulatory framework. VARA was established based on Law No. 2022 of 4 on the Regulation of Virtual Assets in Dubai, the law clarifies Dubai’s forward-looking position in the global virtual asset industry.

Dubai Virtual Assets Regulation LawIt not only provides a legal basis for the issuance, trading, custody and other services of virtual assets, but also demonstrates the Dubai government's vision of attracting global virtual asset companies to settle down through policy support. With this law, Dubai hopes to further consolidate its position as an international fintech hub, attracting innovators, investors and businesses from around the world to enter this rapidly growing market.

VARA License Activity Type

VARA implements detailed and sector-specific supervision on different types of virtual asset activities. Specifically, the following are some of the main areas of regulation:

“Advisory Services” means the making, providing or agreeing to provide personal advice to a client, either at the request of the client or at the initiative of the entity providing the advice, regarding one or more actions or transactions related to any virtual asset.

*Under Regulation 2 - Issuance of Virtual Assets, any entity issuing virtual assets within the Emirate must comply with the VA Issuance Rulebook [the latest version consistent with the date of issuance].

[a] arranging orders for the purchase and/or sale of virtual assets between two entities; [b] soliciting or accepting orders for virtual assets and accepting currency or other virtual assets for such orders; [c] facilitating the matching of virtual asset transactions between buyers and sellers; [d] acting as a dealer in virtual asset transactions on behalf of an entity for its own account; [e] using customer assets to make a market in virtual assets; or [f] providing placement, distribution or other issuance*-related services to customers of virtual assets.

  • “Custody services” means holding virtual assets for or on behalf of another entity and acting solely in accordance with verified instructions issued by or on behalf of that entity.
  • All virtual asset service providers (VASPs) must comply with rules regarding the storage and custody of customer virtual assets. Only VASPs that segregate each customer’s assets in a separate virtual asset wallet are eligible for a custody services license.

"Transaction Services" means any of the following:

[a] exchanging, trading or converting virtual assets for currencies; [b] exchanging, trading or converting one or more virtual assets; [c] matching orders between buyers and sellers and exchanging, trading or converting [i] virtual assets for currencies or [ii] one or more virtual assets; or [d] maintaining an order book for the furtherance of [a], [b] or [c] above.

“Virtual asset management and investment services” means acting as an agent or trustee on behalf of an entity, or otherwise being responsible for the management, administration or disposition of that entity’s virtual assets.
Examples include, but are not limited to:
[a] investment management services or otherwise managing virtual assets; and
[b] Responsible for “staking” virtual assets to earn fees or other value that are paid to validators and/or node operators of “proof-of-stake” distributed ledger technologies.

“Lending service” means the performance of a contract under which a virtual asset is transferred or loaned from one or more parties [lenders] to one or more parties [borrowers], with the borrower undertaking to return it to its interest or on behalf of another person at the request of the lender within the agreed period or at any time at the end of the period.

“Transfer and settlement services” include companies engaged in the transmission or transfer of virtual assets from one entity to another or from one entity to another VA wallet, address, or location.

“Issue Category 1” means, but is not limited to, Fiat Reference Virtual Assets [FRVAs], defined as a type of VA that is intended to maintain a stable value relative to the value of one or more fiat currencies, but does not have legal tender status in any jurisdiction, as defined in more detail in the FRVA Rules.

Entities seeking to obtain a licence from the Virtual Asset Regulatory Authority (VARA) to issue Fiat-Referenced Virtual Assets (FRVA) must comply with all mandatory rulebooks [Firm Rulebook, Compliance and Risk Management Rulebook, Technology and Information Rulebook and Market Conduct Rulebook]. VASPs must also comply with the FRVA rules in Annex 1: Rules for the Issuance of Fiat-Referenced Virtual Assets to the VA Issuance Rulebook.

proprietary trading

VA proprietary trading requires a No Objection Certificate (NoC) from VARA confirming that the activity can be conducted under regulatory supervision without the need for a VA license. In addition, proprietary trading exceeding a certain volume must be registered with VARA. To obtain a proprietary trading NOC, a VASP needs to contact its commercial licensor (free zone or DET) to complete its Initial Disclosure Questionnaire (IDQ).

Virtual Asset Issuance Category 2

All offerings that do not constitute a Category 1 VA Offering and are defined under Part I, Section C, “VA Offering Categories and Prior Requirements” of the VARA Virtual Asset Offering Rulebook

  • Entities must complete the VARA Issuance Approval Form [Category 2] and provide information including the purpose and use of the VA, the nature of the business, and the activities for which the VA will be used.
    • The entity should provide a white paper and complete details of the issuer, among other requirements. VARA may request additional information as it deems necessary for any decision.
    • Entities must demonstrate compliance with Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) requirements.
    • Entities must ensure compliance with technical, information security, data privacy and encryption controls. The use of anonymity-enhanced tokens is prohibited.

Public registers

To ensure transparency and protect consumer rights, VARA maintains a publicly accessible list of Virtual Asset Service Providers (VASPs) that have received either a full license or an In-Principle Approval (IPA). The list provides key information about each provider, including the specific licenses it has and the services it is authorized to provide.

It is important to note that the IPA is issued to applicants as a conditional step in the licensing process, allowing them to complete the final requirements needed to obtain a VASP license.

Applicants holding an IPA are strictly prohibited from conducting business, engaging in any virtual asset activities, or providing services to customers until they obtain a full VASP license issued by VARA.

VASP Name VASP License Reference Permitted Activities License issued Status
Gate Technology FZE VASP License VL/25/04/007 exchange services 2025 January 4 positive
BitGo Custody MENA FZE VASP License VL/25/04/003 Custody services [including custodial pledge] 2025 January 4 positive
Bitpanda Custody MENA DMCC VASP License VL/25/04/006 Custody services [including custodial pledge] 2025 January 4 positive
Atremo Digital FZE VASP License VL/25/04/005 Broker-Dealer Services 2025 January 4 positive
DKK Digital FZE VASP License VL/25/04/002 Broker-Dealer Services 2025 January 4 positive
Bitpanda Broker MENA DMCC VASP License VL/25/03/001 Broker-Dealer Services 2025 January 3 positive
Mantra Finance FZE VASP License VL/25/02/001 exchange services
Broker-Dealer Services
Management and investment services		 2025 January 2 positive
Tokinvest DMCC VASP License VL/2024/12/004 Broker-Dealer Services 2024 January 12 positive
OFZA
Fintech Virtual Asset Exchange
limited liability company		 VASP License VL/24/12/002 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2024 January 12 positive
Sand Bank Private Equity Company VASP License VL/2024/12/001 Hosting services 2024 January 12 positive
BitOasis Technologies FZE VASP License VL/2024/11/001 Broker-Dealer Services 2024 January 11 positive
Deribit FZE VASP License VL/23/12/002 Exchange Services
(Including VA derivatives trading)		 2024 January 11 positive
OKX Middle East Fintech Free Zone Company VASP License VL/23/12/003 Lending Services
Management and investment services
Exchange Services
(Including VA derivatives trading)		 2024 January 9 positive
Web 3 Innovations FZE (AYA) VASP License VL/23/12/001 Management and investment services 2024 January 9 positive
Aquanow ME FZE VASP License VL/24/01/001 Broker-Dealer Services
Management and investment services
Lending Services		 2024 January 7 positive
Safe Labs FZE (Rome) VASP License VL/23/10/001 Broker-Dealer Services 2024 January 7 positive
MEX Digital FZE VASP License VL/24/06/001 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2024 January 7 positive
HT Markets MENA FZE VASP License VL/23/08/003 Broker-Dealer Services
Management and investment services		 2024 January 5 positive
Binance Free Zone VASP License VL/24/04/001 Broker-Dealer Services
Management and investment services
Lending Services
Exchange Services
(Including VA derivatives trading)		 2024 January 4 positive
Foris DAX Middle East FZE (Crypto.com) VASP License VL/23/10/003 Broker-Dealer Services
Management and investment services
Lending Services
Exchange Services
(Including VA derivatives trading)		 2024 January 4 positive
Fassett VASP License VL/23/07/002 Broker-Dealer Services 2023 January 11 positive
CoinMENA FZE VASP License VL/23/09/001 Broker-Dealer Services 2023 January 11 positive
Nine Block Capital Management VASP License VL/23/09/003 Management and investment services 2023 January 11 positive
GC Exchange FZE (GCEX) VASP License VL/23/09/002 Broker-Dealer Services 2023 January 11 positive
Morpheus Software Technology FZE (FUZE) VASP License VL/23/10/002 Broker-Dealer Services 2023 January 11 positive
Hex Trust MENA FZE VASP License VL/23/08/002 Hosting services 2023 January 11 positive
Trek Labs Ltd FZE (Backpack) VASP License VL/23/07/001 exchange services 2023 January 10 positive
Scintilla Network FZE VASP License VL/23/07/001 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2023 January 9 positive
Everything MEA FZE VASP License VL/23/08/001 Custody services [including custodial pledge] 2023 January 8 positive
Laser Digital Middle East Free Zone Company VASP License VL/23/06/001 Broker-Dealer Services
Management and investment services		 2023 January 7 positive
VASP Name License plate type Reference Permitted Activities License issued Status
Sand Bank Private Equity Company VASP License VL/2024/12/001 Hosting services 2024 January 12 positive
Hex Trust MENA FZE VASP License VL/23/08/002 Hosting services 2023 January 11 positive
VASP Name License plate type Reference Permitted Activities License issued Status
Gate Technology FZE VASP License VL/25/04/007 exchange services 2025 January 4 positive
Mantra Finance FZE VASP License VL/25/02/001 exchange services
Broker-Dealer Services
Management and investment services		 2025 January 2 positive
OFZA
Fintech virtual asset trading
All limited liability companies		 VASP License VL/24/12/002 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2024 January 12 positive
MEX Digital FZE VASP License VL/24/06/001 Broker-Dealer Services
exchange services		 2024 January 7 positive
Trek Labs Ltd FZE (Backpack) VASP License VL/23/07/001 exchange services 2023 January 10 positive
Scintilla Network FZE VASP License VL/23/07/001 Broker-Dealer Services
exchange services		 2023 January 9 positive
VASP Name License Type reference Permitted Activities License issued Status
BitGo Custody MENA FZE VASP License VL/25/04/003 Custody services [including custodial pledge] 2025 January 4 positive
Bitpanda Custody MENA DMCC VASP License VL/25/04/006 Custody services [including custodial pledge] 2025 January 4 positive
Everything MEA FZE VASP License VL/23/08/001 Custody services [including custodial pledge] 2023 January 8 positive
VASP Name License plate type Reference Permitted Activities License issued Status
Atremo Digital FZE VASP License VL/25/04/005 Broker-Dealer Services 2025 January 4 positive
DKK Digital FZE VASP License VL/25/04/002 Broker-Dealer Services 2025 January 4 positive
Bitpanda Broker MENA DMCC VASP License VL/25/03/001 Broker-Dealer Services 2025 January 3 positive
Mantra Finance FZE VASP License VL/25/02/001 exchange services
Broker-Dealer Services
Management and investment services		 2025 January 2 positive
Tokinvest DMCC VASP License VL/2024/12/004 Broker-Dealer Services 2024 January 12 positive
OFZA
Fintech Virtual Asset Exchange
limited liability company		 VASP License VL/24/12/002 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2024 January 12 positive
BitOasis Technologies FZE VASP License VL/2024/11/001 Broker-Dealer Services 2024 January 11 positive
Aquanow ME FZE VASP License VL/24/01/001 Broker-Dealer Services
Management and investment services
Lending Services		 2024 January 7 positive
Safe Labs FZE (Rome) VASP License VL/23/10/001 Broker-Dealer Services 2024 January 7 positive
MEX Digital FZE VASP License VL/24/06/001 Broker-Dealer Services
exchange services		 2024 January 7 positive
HT Markets MENA FZE VASP License VL/23/08/003 Broker-Dealer Services
Management and investment services		 2024 January 5 positive
Binance Free Zone VASP License VL/24/04/001 Broker-Dealer Services
Management and investment services
Lending Services
Exchange services (including VA derivatives trading)		 2024 January 4 positive
Foris DAX Middle East FZE (Crypto.com) VASP License VL/23/10/003 Broker-Dealer Services
Management and investment services
Lending Services
Exchange services (including VA derivatives trading)		 2024 January 4 positive
Fassett VASP License VL/23/07/002 Broker-Dealer Services 2023 January 11 positive
CoinMENA FZE VASP License VL/23/09/001 Broker-Dealer Services 2023 January 11 positive
GC Exchange FZE (GCEX) VASP License VL/23/09/002 Broker-Dealer Services 2023 January 11 positive
Morpheus Software Technology FZE (FUZE) VASP License VL/23/10/002 Broker-Dealer Services 2023 January 11 positive
Scintilla Network FZE VASP License VL/23/07/001 Broker-Dealer Services
exchange services		 2023 January 9 positive
Laser Digital Middle East Free Zone Company VASP License VL/23/06/001 Broker-Dealer Services
Management and investment services		 2023 January 7 positive
VASP Name License plate type Reference Permitted Activities License issued Status
Mantra Finance FZE VASP License VL/25/02/001 exchange services
Broker-Dealer Services
Management and investment services		 2025 January 2 positive
OFZA
Fintech Virtual Asset Exchange
limited liability company		 VASP License VL/24/12/002 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2024 January 12 positive
OK
Fintech in the Middle East
Free Zone Company		 VASP License VL/23/12/003 Lending Services
Management and investment services
Exchange services (including VA derivatives trading)		 2024 January 9 positive
Web 3 Innovations FZE (AYA) VASP License VL/23/12/001 Management and investment services 2024 January 9 positive
Aquanow ME FZE VASP License VL/24/01/001 Broker-Dealer Services
Management and investment services
Lending Services		 2024 January 7 positive
HT Markets MENA FZE VASP License VL/23/08/003 Broker-Dealer Services
Management and investment services		 2024 January 5 positive
Binance Free Zone VASP License VL/24/04/001 Broker-Dealer Services
Management and investment services
Lending Services
Exchange services (including VA derivatives trading)		 2024 January 4 positive
Foris DAX Middle East FZE (Crypto.com) VASP License VL/23/10/003 Broker-Dealer Services
Management and investment services
Lending Services
Exchange services (including VA derivatives trading)		 2024 January 4 positive
Nine Block Capital Management VASP License VL/23/09/003 Management and investment services 2023 January 11 positive
Laser Digital
Middle East Free Zone Company		 VASP License VL/23/06/001 Broker-Dealer Services
Management and investment services		 2023 January 7 positive
VASP Name VASP License Reference Permitted Activities License issued Status
Gate Technology FZE VASP License VL/25/04/007 exchange services 2025 January 4 positive
BitGo Custody MENA FZE VASP License VL/25/04/003 Custody services [including custodial pledge] 2025 January 4 positive
Bitpanda Custody MENA DMCC VASP License VL/25/04/006 Custody services [including custodial pledge] 2025 January 4 positive
Atremo Digital FZE VASP License VL/25/04/005 Broker-Dealer Services 2025 January 4 positive
DKK Digital FZE VASP License VL/25/04/002 Broker-Dealer Services 2025 January 4 positive
Bitpanda Broker MENA DMCC VASP License VL/25/03/001 Broker-Dealer Services 2025 January 3 positive
Mantra Finance FZE VASP License VL/25/02/001 exchange services
Broker-Dealer Services
Management and investment services		 2025 January 2 positive
Tokinvest DMCC VASP License VL/2024/12/004 Broker-Dealer Services 2024 January 12 positive
OFZA
Fintech Virtual Asset Exchange
limited liability company		 VASP License VL/24/12/002 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2024 January 12 positive
Sand Bank Private Equity Company VASP License VL/2024/12/001 Hosting services 2024 January 12 positive
BitOasis Technologies FZE VASP License VL/2024/11/001 Broker-Dealer Services 2024 January 11 positive
Deribit FZE VASP License VL/23/12/002 Exchange Services
(Including VA derivatives trading)		 2024 January 11 positive
OKX Middle East Fintech Free Zone Company VASP License VL/23/12/003 Lending Services
Management and investment services
Exchange Services
(Including VA derivatives trading)		 2024 January 9 positive
Web 3 Innovations FZE (AYA) VASP License VL/23/12/001 Management and investment services 2024 January 9 positive
Aquanow ME FZE VASP License VL/24/01/001 Broker-Dealer Services
Management and investment services
Lending Services		 2024 January 7 positive
Safe Labs FZE (Rome) VASP License VL/23/10/001 Broker-Dealer Services 2024 January 7 positive
MEX Digital FZE VASP License VL/24/06/001 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2024 January 7 positive
HT Markets MENA FZE VASP License VL/23/08/003 Broker-Dealer Services
Management and investment services		 2024 January 5 positive
Binance Free Zone VASP License VL/24/04/001 Broker-Dealer Services
Management and investment services
Lending Services
Exchange Services
(Including VA derivatives trading)		 2024 January 4 positive
Foris DAX Middle East FZE (Crypto.com) VASP License VL/23/10/003 Broker-Dealer Services
Management and investment services
Lending Services
Exchange Services
(Including VA derivatives trading)		 2024 January 4 positive
Fassett VASP License VL/23/07/002 Broker-Dealer Services 2023 January 11 positive
CoinMENA FZE VASP License VL/23/09/001 Broker-Dealer Services 2023 January 11 positive
Nine Block Capital Management VASP License VL/23/09/003 Management and investment services 2023 January 11 positive
GC Exchange FZE (GCEX) VASP License VL/23/09/002 Broker-Dealer Services 2023 January 11 positive
Morpheus Software Technology FZE (FUZE) VASP License VL/23/10/002 Broker-Dealer Services 2023 January 11 positive
Hex Trust MENA FZE VASP License VL/23/08/002 Hosting services 2023 January 11 positive
Trek Labs Ltd FZE (Backpack) VASP License VL/23/07/001 exchange services 2023 January 10 positive
Scintilla Network FZE VASP License VL/23/07/001 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2023 January 9 positive
Everything MEA FZE VASP License VL/23/08/001 Custody services [including custodial pledge] 2023 January 8 positive
Laser Digital Middle East Free Zone Company VASP License VL/23/06/001 Broker-Dealer Services
Management and investment services		 2023 January 7 positive
VASP Name License plate type Reference Permitted Activities License issued Status
Deribit FZE VASP License VL/23/12/002 Exchange services (including VA derivatives trading) 2024 January 11 positive
OK
Fintech in the Middle East
Free Zone Company		 VASP License VL/23/12/003 Lending Services
Management and investment services
Exchange services (including VA derivatives trading)		 2024 January 9 positive
Binance Free Zone VASP License VL/24/04/001 Broker-Dealer Services
Management and investment services
Lending Services
Exchange services (including VA derivatives trading)		 2024 January 4 positive
Foris DAX Middle East FZE (Crypto.com) VASP License VL/23/10/003 Broker-Dealer Services
Management and investment services
Lending Services
Exchange services (including VA derivatives trading)		 2024 January 4 positive
VASP Name License plate type Reference Permitted Activities License issued Status
OK
Fintech in the Middle East
Free Zone Company		 VASP License VL/23/12/003 Lending Services
Management and investment services
Exchange services (including VA derivatives trading)		 2024 January 9 positive
Aquanow ME FZE VASP License VL/24/01/001 Broker-Dealer Services
Management and investment services
Lending Services		 2024 January 7 positive
Binance Free Zone VASP License VL/24/04/001 Broker-Dealer Services
Management and investment services
Lending Services
Exchange services (including VA derivatives trading)		 2024 January 4 positive
Foris DAX Middle East FZE (Crypto.com) VASP License VL/23/10/003 Broker-Dealer Services
Management and investment services
Lending Services
Exchange services (including VA derivatives trading)		 2024 January 4 positive
VASP Name VASP License Reference Permitted Activities License issued Status
Gate Technology FZE VASP License VL/25/04/007 exchange services 2025 January 4 positive
BitGo Custody MENA FZE VASP License VL/25/04/003 Custody services [including custodial pledge] 2025 January 4 positive
Bitpanda Custody MENA DMCC VASP License VL/25/04/006 Custody services [including custodial pledge] 2025 January 4 positive
Atremo Digital FZE VASP License VL/25/04/005 Broker-Dealer Services 2025 January 4 positive
DKK Digital FZE VASP License VL/25/04/002 Broker-Dealer Services 2025 January 4 positive
Bitpanda Broker MENA DMCC VASP License VL/25/03/001 Broker-Dealer Services 2025 January 3 positive
Mantra Finance FZE VASP License VL/25/02/001 exchange services
Broker-Dealer Services
Management and investment services		 2025 January 2 positive
Tokinvest DMCC VASP License VL/2024/12/004 Broker-Dealer Services 2024 January 12 positive
OFZA
Fintech Virtual Asset Exchange
limited liability company		 VASP License VL/24/12/002 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2024 January 12 positive
Sand Bank Private Equity Company VASP License VL/2024/12/001 Hosting services 2024 January 12 positive
BitOasis Technologies FZE VASP License VL/2024/11/001 Broker-Dealer Services 2024 January 11 positive
Deribit FZE VASP License VL/23/12/002 Exchange Services
(Including VA derivatives trading)		 2024 January 11 positive
OKX Middle East Fintech Free Zone Company VASP License VL/23/12/003 Lending Services
Management and investment services
Exchange Services
(Including VA derivatives trading)		 2024 January 9 positive
Web 3 Innovations FZE (AYA) VASP License VL/23/12/001 Management and investment services 2024 January 9 positive
Aquanow ME FZE VASP License VL/24/01/001 Broker-Dealer Services
Management and investment services
Lending Services		 2024 January 7 positive
Safe Labs FZE (Rome) VASP License VL/23/10/001 Broker-Dealer Services 2024 January 7 positive
MEX Digital FZE VASP License VL/24/06/001 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2024 January 7 positive
HT Markets MENA FZE VASP License VL/23/08/003 Broker-Dealer Services
Management and investment services		 2024 January 5 positive
Binance Free Zone VASP License VL/24/04/001 Broker-Dealer Services
Management and investment services
Lending Services
Exchange Services
(Including VA derivatives trading)		 2024 January 4 positive
Foris DAX Middle East FZE (Crypto.com) VASP License VL/23/10/003 Broker-Dealer Services
Management and investment services
Lending Services
Exchange Services
(Including VA derivatives trading)		 2024 January 4 positive
Fassett VASP License VL/23/07/002 Broker-Dealer Services 2023 January 11 positive
CoinMENA FZE VASP License VL/23/09/001 Broker-Dealer Services 2023 January 11 positive
Nine Block Capital Management VASP License VL/23/09/003 Management and investment services 2023 January 11 positive
GC Exchange FZE (GCEX) VASP License VL/23/09/002 Broker-Dealer Services 2023 January 11 positive
Morpheus Software Technology FZE (FUZE) VASP License VL/23/10/002 Broker-Dealer Services 2023 January 11 positive
Hex Trust MENA FZE VASP License VL/23/08/002 Hosting services 2023 January 11 positive
Trek Labs Ltd FZE (Backpack) VASP License VL/23/07/001 exchange services 2023 January 10 positive
Scintilla Network FZE VASP License VL/23/07/001 Broker-Dealer Services
exchange services
Management and investment services
諮詢服務		 2023 January 9 positive
Everything MEA FZE VASP License VL/23/08/001 Custody services [including custodial pledge] 2023 January 8 positive
Laser Digital Middle East Free Zone Company VASP License VL/23/06/001 Broker-Dealer Services
Management and investment services		 2023 January 7 positive

Customer service type

Based on the client's actual background and business needs, Aiying will have an in-depth understanding of the client's business model and needs, and tailor a unique application strategy and solution to ensure that each service perfectly matches the client's personalized needs.

Asset Management Institutions

Asset Manager

Lending Institutions

loan provider

Exchange

cryptocurrency exchange

Crypto Custody

crypto custody

Brokerage Institutions

broker-dealer

OTC institutions

OTC provider

Application Steps Guide

Before beginning the application process, first determine the jurisdiction in which you wish to conduct your virtual asset business.

Each customer has different business conditions and future development plans. After comprehensive evaluation by Aiying(NH), we will provide customers with a solution that matches their business development.

Gather all necessary documents required to apply for your license. These documents include business plans, financial statements, compliance manuals, AML/KYC procedures, corporate governance documents, and details of shareholders and directors.

When applying for a virtual asset license in the UAE, you will need to provide a complete set of detailed documents and information to the regulatory agency responsible for supervising virtual asset business licenses. These documents are critical for regulators to assess your business operations, ensure compliance with regulatory requirements, and mitigate potential risks. The following is an overview of the documents and information that are typically required during the application process:

business plan

▪ A detailed business plan outlining your company's objectives, proposed activities, target markets, competitive analysis, and financial projections.

▪ Describe products or services related to virtual assets, such as virtual asset exchanges, wallet services, tokenization platforms, or ICO (initial coin offering) launch platforms.

Company Files

▪ The company’s certificate of incorporation and its articles and by-laws.

▪ Shareholders' agreement (if applicable).

▪ A board resolution authorizing the application for a virtual asset business license and appointing key personnel responsible for regulatory compliance.

Ownership and Management Information

▪ Details of the company’s shareholders, directors and senior management, including name, contact details, passport copies and residential addresses.

▪ An organizational chart outlining the company structure and the hierarchical relationships of key personnel.

Compliance and regulatory documentation

▪ Anti-Money Laundering (AML) and Know Your Customer (KYC) Policies and Procedures, detailing how the Company complies with AML and KYC regulations.

▪ A compliance manual outlining internal controls, risk management procedures, and protocols for detecting and reporting suspicious activity.

▪ Demonstration of compliance with international standards and best practices in countering the financing of terrorism (CFT) measures.

financial information

▪ Audited financial statements for the past three years (if applicable), including balance sheet, profit and loss statement and cash flow statement.

▪ Financial projections for the next three to five years, demonstrating the viability and sustainability of your business model.

▪ Bank reference letter and proof of financial solvency, demonstrating the company’s financial stability and ability to operate a virtual asset business.

Technical documentation

▪ Describe your IT infrastructure, cyber security measures, and data protection protocols to ensure the security and integrity of the virtual asset platform.

▪ Details of any third-party suppliers or service providers involved in the development, maintenance or operation of virtual asset-related technologies.

Legal and Compliance Documents

▪ Demonstrate compliance with local laws and regulations governing virtual asset businesses in the UAE, including business licenses, permits and approvals obtained from relevant regulatory authorities.

▪ A legal opinion or memorandum prepared by qualified legal counsel addressing specific regulatory issues relevant to your virtual asset activities.

Other support files

▪ Any other documents or information required by the regulatory authorities during the application process.

▪ A letter of recommendation or reference from a reputable individual or organization confirming your company’s credibility, integrity, and suitability to operate a virtual asset business.

Fill out the virtual asset business license application form provided by the regulatory authority. Ensure that all information provided is accurate and up to date.

Pay any applicable fees associated with your business license application. Fees may vary depending on the type of business license and jurisdiction.

Once the application is submitted, the regulator will review the dossier and conduct due diligence on the applicant and its proposed business activities. Depending on the complexity of the application and the workload of the regulatory agency, the review process may take from a few weeks to a few months.

During the review process, the regulator may request additional information or clarification of certain aspects of the application. Aiying (NH) will assist customers in responding to inquiries and providing required information in a timely manner to speed up the review process.

If the application is approved, you will receive a notification from the regulator and receive a virtual asset business license. Ensure compliance with any conditions or requirements set out in the business licence approval.

Once you obtain a virtual asset business license, you can start operating in accordance with the regulatory framework and conditions set out in the business license. Ensure ongoing compliance with regulatory requirements and maintain appropriate records and reports as per regulatory standards.

Application timetable

Phase 1 (preliminary approval):

Step 1: Start collaboration and designate a team and project leader

1 weeks

Step 2: Monitor business plan, application preparation and submission, follow up video/telephone communication

2 weeks

Phase 2 (Review and Approval):

Company registration, office rental

2 weeks

Submit regulatory business plan to regulatory agency and confirm project plan document list. Regulatory agencies review supporting documentation.

1-2 months

Approval in Principle

3 weeks

Submit your application and required documents. Wait for the regulatory authorities to review the application and provide clarification if necessary.

2 weeks

→ Review passed?

Yes: The regulator issues a Virtual Asset Service Provider (VASP) operating license.

3 weeks to 1 month

No: Respond to all comments or questions. Prepare regulatory applications while reviewing agency changes to policies and procedures.

2 weeks

Phase 3(Obtain business license) :

  • Visa application process
  • Assist with bank account opening and deposit of required share capital
  • Obtain a letter from the bank confirming the account balance
  • Assist with processing fast conditions (if applicable)
  • Ongoing compliance
  • Renew every year

Team members introduction

Naoual Haddouch - partner

Naoual HaddouchAn outstanding corporate and innovation lawyer with nearly ten years of experience. Naoual played a key role in developing the government’s economic strategy, driving regulatory reforms and promoting effective governance practices.

As a strategic advisor, she has in-depth knowledge of the UAE’s legislative process, economic trends and socio-political dynamics. Naoual is widely recognized for his ability to analyze complex challenges, develop innovative solutions, and foster consensus among diverse stakeholders.

Naoual is known for her mastery of business and government strategy, providing strategic insight and visionary leadership to her collaborators.

Naoual holds a Master of Laws from the Rotterdam University of Applied Sciences, a Bachelor of Business Administration (specialization in Real Estate Development) from the Rotterdam University of Applied Sciences, a postgraduate degree in Financial Markets, Finance and Financial Management Services and a Master of Corporate Governance from Yale University.

Her deep understanding of the regulatory environment and ability to navigate its complexity make her a trusted advisor, providing strategic insight and visionary leadership to collaborators.

Tao Xiao – partner

Tao Xiaois an experienced investment manager and advisor known for his expertise in fintech and investment strategy. She specializes in helping entrepreneurs establish businesses and gain access to advanced business environments in the UAE and GCC region.

Ms. Tao has played an important role in guiding numerous companies through the intricacies of initial public offerings (IPOs) and their successful entry into the public markets. Her expertise also includes nurturing public companies, promoting their growth and expanding their investment horizons.

With a Master's degree in IT, Tao combines technical understanding with global financial markets. She specializes in guiding companies through initial public offerings and expanding their investment potential.

Ms. Tao’s career highlights include significant achievements in partnerships with technology companies, leveraging her deep understanding of finance and technology to drive innovation and growth strategies.

FAQs

Aiying has accumulated a lot of experience in customer service, providing customers with flexible and professional answers

  • answer :

    • STICK License Type: VARA Seven categories of virtual asset activities are defined, including: 1) Trading services (Exchange), 2) Transfer and settlement services, 3) Hosting and management services, 4) Brokerage trading services, 5) Investment and financing services, 6) Issuance and distribution services, 7) Consulting services. Your organization will need to tailor its business model (e.g. NFT The market may involve issuance and trading, DeFi The platform may involve financing and settlement) select the corresponding category.

    • Prerequisites :
      • Registered Entity: In Dubai (mainland or free zone, such as To establish a legal entity in DMCC, you need to provide company charter, shareholder information, etc.
      • Minimum capital：Depending on the type of activity, capital requirements vary from 50,000 To 500,000 Dirham (AED) varies. For example, an exchange may require higher capital to demonstrate financial stability.
      • governance structure: Submit proof of senior management qualifications (no criminal record required) and prove technical and operational capabilities.

      • AML/CFT ready:Establish KYC / AML system, appointing a qualified Money Laundering Reporting Officer (MLRO).

    • application process :
      1. Submit a Letter of Intent (LOI) to VARA, outline business model.
      2. Enter the preliminary approval stage and provide a detailed business plan, risk assessment and technical architecture.
      3. If approved, it will enter the comprehensive application stage and submit compliance documents and audit reports.
      4. Get a temporary license (MVP Permit) or formal licensing, a process that is usually time-consuming 3-6 Months.
    • Suggest:and STICK Communicate upfront to determine if your business will require more than one license (e.g., an exchange and custodian). Hire a local compliance consultant (such as Aiying (NH)It speeds up the process.
  • answer :
    • challenge :
      • Bank cooperation restrictions:part UAE Bank AML Risks, and limited support for account opening and trading of virtual asset businesses.
      • regulatory requirements: VARA Requires legal currency-virtual asset conversion to comply with KYC / AML rules and ensure transparency of funding sources.

      • Technical compatibility：Banking systems usually do not directly support blockchain settlement and require intermediate layer technology (such as payment gateways).

    • solution strategy :
      • Choose a partner bank :
        • Partner with crypto-friendly banks like Emirates NBD, Mashreq Bank Or RAKBANK, these banks have begun to support virtual asset businesses.
        • In free zones (such as DIFC) to open a bank account, as banks in these areas are more familiar with Web3 business.
      • Payment Gateway Integration :
        • Use a payment processor that supports virtual assets (such as bitoasis Or CoinPayments), which provides instant fiat-to-cryptocurrency exchange.
        • Ensure payment systems comply with UAE The central bank’s electronic payment regulations and support multiple currencies (AED, USD, EUR).
      • Compliance measures :
        • Implement real-time KYC / AML Screening, sharing compliance data with banks, enhancing trust.
        • Submit fund flow reports to STICK 和 UAE The Financial Intelligence Unit (FIU), certifies the legitimacy of transactions.
      • Technical solutions :
        • Deployment of blockchain-bank bridge protocols (such as RippleNet Or Stellar) to achieve fast settlement.

        • Using stablecoins (such as USDC) as a fiat alternative, reducing volatility and simplifying exchange.

    • Case reference : bitoasis by with mashreq Bank Cooperation, provide AED Fiat currency deposits and withdrawals significantly increase user adoption.

    • Suggestions for action :
      • Act Now:connect Emirates NBD Or DIFC Bank to discuss business account opening (1 within one month).
      • Short-term goals:in 3 Sign a contract with a payment gateway provider within a month and complete the testing of the fiat-crypto exchange function.
      • long term plan:and UAE The central bank is exploring the integration of central bank digital currency (CBDC) and planning for the future in advance 2-3 The financial ecology of the year.
answer :
  • Core elements of a compliance program :
    • KYC Process: Implement multiple layers of identity verification, including ID, proof of address, and source of funds checks. VARA requires initial and ongoing screening of all customers and enhanced due diligence (EDD) for high-risk customers such as politically exposed persons (PEPs).
    • Transaction monitoring: Deploy real-time monitoring systems (such as Chainalysis or Elliptic) to detect abnormal transaction patterns, such as large transfers or wallet addresses associated with sanctions lists.
    • reporting obligations: Submit a suspicious transaction report (STR) to the Financial Intelligence Unit (FIU) of the Central Bank of the UAE, usually within 14 days.
    • MLRO Role: Appoint a reporting officer with AML/CFT professional qualifications to be responsible for internal policy development, staff training and liaison with regulators.

    • Sanctions Screening: Ensure that the platform does not trade with entities on the OFAC, UN or UAE sanctions lists and update the blacklist database regularly.

  • Technical implementation :
    • Use blockchain analysis tools to track the flow of funds and ensure transparency.

    • Implement smart contract audits to prevent vulnerabilities from being used for money laundering.

  • Training and Audit :
    • Conduct regular AML/CFT training for employees covering the latest regulatory requirements and case studies.

    • Conduct internal or third-party compliance audits annually to ensure system effectiveness.

  • VARA Specific Requirements :
    • Refer to FATF’s virtual asset recommendations (such as the Travel Rule) to ensure that cross-border transactions contain sender and receiver information.
    • Submit an AML/CFT policy as part of your licence application, covering risk assessment and mitigation measures.
  • Suggest: Partnered with VARA and participated in its AML/CFT training courses. Invest in sophisticated compliance software to reduce the risk of human error.
answer :
  • Legality of Smart Contracts :
    • Legal Status: UAE law has not yet fully clarified the legal effect of smart contracts, but the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM) recognize them as enforceable electronic contracts, provided that traditional contract elements (offer, acceptance, consideration, intention) are met.
    • Compliance requirements：Smart contracts need to contain clear terms (such as refund mechanisms, dispute resolution methods) and be audited by a third party to ensure there are no loopholes. VARA may require the submission of contract code audit reports.

    • dispute resolution: Designate Dubai Courts or DIFC Courts as the dispute resolution body in the smart contract and specify the applicable law (UAE law or common law).

  • Compliance of tokenized assets :
    • Asset Classification: VARA divides virtual assets into security, utility and payment tokens. Security tokens are subject to securities laws (such as SCA regulation), and utility tokens (such as NFTs) are subject to consumer protection laws.
    • Disclosure requirements: Before issuing tokens, a white paper must be submitted to VARA, detailing the token functions, distribution plan, and risk disclosure.

    • consumer protection: Ensure that token sales do not involve misleading marketing and comply with UAE advertising regulations.

  • Risk Mitigation :
    • Hire a law firm familiar with blockchain law, such as Aiying (NH), to draft the contract and white paper.
    • Implement decentralized identity verification (DID) to enhance transaction transparency and reduce the risk of fraud.
    • Purchase professional liability insurance to protect against potential legal action.
  • Suggest: Confirm with VARA the specific regulatory requirements for smart contracts and consider registering in DIFC to take advantage of its more mature legal framework.
answer :
  • Cybersecurity standards :
    • Follow international standards such as ISO 27001 (Information Security Management) or NIST 800-53 (Cybersecurity Framework).
    • Implement multi-signature wallets (Multi-Sig) and hardware security modules (HSM) to protect user assets.

    • Perform penetration tests and vulnerability scans regularly, and hire a third-party security company (such as Hacken or CertiK) to perform audits.

  • Data Privacy Compliance :
    • Comply with the UAE Federal Data Protection Law (2021) to ensure that user data is stored encrypted and with explicit consent.
    • Implement zero-knowledge proof (ZKP) or homomorphic encryption technology to protect user privacy while meeting regulatory requirements.

    • Develop a data breach contingency plan and report significant incidents to VARA and affected users within 72 hours.

  • Infrastructure requirements :
    • Local storage: VARA may require that some data (such as KYC records) be stored within the UAE and must cooperate with local cloud service providers (such as AWS Middle East Region).

    • High availability: Ensure 99.99% platform uptime, achieved through distributed nodes and disaster recovery plans.

  • Auditing and reporting :
    • Submit annual safety audit reports to demonstrate compliance with VARA's technical standards.
    • Implement a continuous monitoring system to record all safety incidents and archive them for regulatory review.
  • Suggest: Invest in enterprise-grade security solutions and work with VARA Technology to ensure the infrastructure design meets their expectations.
answer :
  • Free Zone Tax Advantages :
    • In Dubai's free zones (such as DMCC and DIFC), companies can enjoy 0% corporate income tax (for at least 15-50 years, depending on the free zone policy) and 0% personal income tax.
    • Virtual asset transactions are generally exempt from Value Added Tax (VAT), but if service fees are involved (such as transaction fees), 5% VAT may be required.

    • The free zone allows 100% foreign ownership and full repatriation of profits, making it suitable for international Web3 businesses.

  • Mainland tax requirements :
    • From June 2023, the UAE imposes a 6% corporate income tax (on profits exceeding AED 9), but capital gains from virtual assets may be tax-exempt (subject to confirmation of the specific business model).

    • Mainland companies will need to comply with stricter financial reporting requirements, which may increase compliance costs.

  • financial planning advice :
    • Choose a Free Zone: If your business mainly serves international clients, choosing DMCC or DIFC can maximize tax benefits.
    • VAT compliance: Ensure that VAT is correctly reported on transaction fees and service income, and keep detailed records to cope with audits.

    • Cross-border taxation: If you serve international clients, you need to consider the withholding tax (WHT) issue in the source country. The bilateral tax agreements signed by the UAE with many countries can reduce the burden.

  • Suggest : Hire an accounting firm familiar with UAE tax laws (such as PwC or EY) and confirm the tax treatment of virtual asset transactions with VARA in the early stages of business establishment.
answer :
  • Regulatory trends :
    • VARA could introduce stricter capital requirements or restrictions on high-risk assets (such as privacy coins), referring to the FATF and EU MiCA frameworks.
    • Expect increased regulation of stablecoins and DeFi platforms, potentially requiring additional disclosures or licensing.

    • Cross-jurisdictional cooperation is likely to increase, subject to compliance with international standards (such as the Travel Rule).

  • flexible strategy :
    • Modular Compliance: Design scalable compliance systems that allow KYC/AML processes to be quickly adjusted to new requirements.
    • Technology adaptability: Use upgradeable smart contracts and a modular blockchain architecture to allow for rapid modification of functionality as regulatory requirements change.
    • Diversified markets: In addition to Dubai, consider setting up an alternate operating base in ADGM or Singapore to diversify regulatory risks.

    • Cooperate with regulators: Regularly participate in VARA’s public consultation meetings to provide industry feedback and learn about policy trends in advance.

  • Risk Management :
    • Establish contingency plans for regulatory changes, such as setting aside additional capital to cope with new requirements.
    • Purchase compliance insurance to protect against potential regulatory fines.
  • Suggest: Join industry associations such as Dubai Blockchain Center to obtain policy updates and establish long-term communication channels with VARA.
answer :
  • Cross-border regulatory challenges :
    • internationality AML/CFT Claim:according to Fatf Of Travel Rule, cross-border virtual asset transfers must be accompanied by the identity information of the sender and receiver. VARA Enterprises are required to implement corresponding systems to ensure alignment with international standards.
    • Jurisdictional Conflicts：Some countries (such as the United States) may consider certain tokens as securities and need to comply with SEC Rules, while Dubai may regard it as a utility token, and the applicable law needs to be clarified.

    • data privacy：Serving EU customers must comply with GDPR, possibly related to UAE There are differences in data protection laws and privacy policies need to be unified.

  • solution strategy :
    • Zoning Compliance: Customized design for different markets (e.g. EU, Asia) KYC / AML process, using configurable compliance software such as Sumsub Or ComplyAdvantage) supports multi-country requirements.
    • legal advice: Hire an international law firm (such as DLA Piper provides cross-jurisdictional legal analysis to ensure token classification and business models are compliant in major markets.
    • Technical solutions: Implement blockchain interoperability protocols (such as Polkadot Or Cosmos), allows interaction with blockchain networks in different regulatory environments and records compliance data.

    • STICK Teaching:and STICK Identify specific requirements for cross-border operations, such as whether additional licenses or data sharing with foreign regulators are required.

  • Case reference：Binance When operating in Dubai, through localization KYC and STICK Collaborate closely to successfully address cross-border compliance challenges.

  • Suggest: Establish a global compliance team focused on monitoring international regulatory changes and working with STICK Communicate cross-border business plans regularly. Consider DIFC Registered, taking advantage of its international legal framework.
answer :
  • VARA Eligibility Requirements :
    • Executives: The CEO, CFO, and compliance officer must have 5-10 years of experience in the financial or technology industry, have a clean criminal record, and pass VARA's "eligibility" review.
    • Money Laundering Reporting Officer (MLRO): Must hold CAMS (Certified Anti-Money Laundering Specialist) or equivalent qualification and be familiar with the risks of virtual assets.

    • Technical team：Blockchain engineers and cybersecurity experts need to demonstrate relevant project experience and may need to submit code audits or security certifications.

  • Local talent challenge :
    • Dubai’s Web3 talent pool is limited, especially in the areas of smart contract development and compliance, leading to high salary competition.

    • Foreign employees need to apply for work visas, which increases recruitment costs and time. (Aiying (NH) can provide corresponding services and assistance)

  • Suggest : When applying for a license, detailed team structure and qualifications are submitted to VARA. Work with HR departments in Dubai free zones such as DMCC to streamline visa processes for expatriate employees.
answer :
  • Financing Challenges :
    • VARA requires disclosure of the source of funds, and anonymity of international investors may be limited.
    • Token issuance (such as ICO or IDO) is subject to the securities laws and disclosure requirements of VARA, which may increase compliance costs.

    • Middle Eastern investors prefer low-risk, high-transparency projects that demonstrate a robust business model.

  • Financing strategy :
    • Compliance token issuance :
      • Submit a detailed white paper to VARA, clarifying the nature of the token (utility or security), distribution plan and risk disclosure.
      • Consider conducting an STO (Security Token Offering) in DIFC and leverage its mature securities regulatory framework to attract institutional investors.
    • Equity financing :
      • Partner with a Dubai-based venture capital fund like Shorooq Partners or Hala Ventures to avoid the regulatory complexities of a token offering through equity financing.
      • Leverage the free zone’s 0% tax rate and 100% foreign ownership to attract international VCs.
    • governmental support :
      • Apply for funding from Dubai Future Accelerators or DMCC Crypto Centre for seed funding or incubation support.
      • Cooperate with the UAE Central Bank or Dubai Economy to explore pilot projects related to digital assets.
    • Investor attractiveness :
      • Provide transparent financial projections and compliance records to demonstrate a good relationship with VARA.

      • Emphasize Dubai’s strategic location (connecting Europe, Asia and Africa) to attract investors seeking global expansion.

  • Case reference：Ripple has attracted investment from Middle Eastern sovereign wealth funds in Dubai through cooperation with local banks and compliance operations.

  • Suggest: Hire financial advisors (such as Deloitte) to design a compliant financing structure and attend investment summits in Dubai (such as AIM Summit) to connect with potential investors.
answer :
  • ESG Challenges :
    • Environment: PoW blockchains such as Bitcoin have high energy consumption, which may conflict with Dubai’s low-carbon goals.
    • society: Need to ensure that Web3 services promote financial inclusion, especially for low-income groups in the Middle East and Africa.

    • Governance: Transparent token distribution and anti-corruption measures are critical to attracting institutional investors.

  • solution strategy :
    • environmental sustainability :
      • Choose a low-energy blockchain (such as Ethereum’s PoS, Solana, or Polygon) to reduce your carbon footprint.
      • Collaborate with renewable energy projects in the UAE, such as Masdar, to support node operations using green energy.
      • Report carbon emissions publicly and purchase carbon credits (such as through Verra) to offset the impact.
    • social influence :
      • Launch low-threshold Web3 products (such as micro-investment platforms or free NFT creation tools) to serve users in emerging markets.
      • Partner with local NGOs to increase social impact through tokenized charity projects such as education or healthcare crowdfunding.
    • Transparent governance :
      • Implement a decentralized autonomous organization (DAO) structure to make governance decisions and fund usage public.

      • Regularly undergo third-party governance audits (such as PwC) to ensure there is no insider trading or conflicts of interest.

  • investment attractiveness :
    • Publish an ESG report to demonstrate contribution to Dubai’s 2050 strategy and attract Middle Eastern sovereign wealth funds such as Mubadala.

    • Attend ESG investment conferences, such as the Abu Dhabi Sustainable Finance Forum, to network with green investors.

  • Case reference : Algorand has attracted the attention of sustainable investors through its carbon-burdened blockchain and ESG commitment.
  • Suggestions for action :
    • Act Now: Review the energy consumption of your blockchain technology and choose a PoS protocol (within 1 month).
    • Short-term goals: Release the first ESG report within 3-6 months and discuss energy cooperation with Masdar.
    • long term plan: Launch a social impact project (such as a tokenized education fund) within 12 months to enhance brand reputation.
  1. Proprietary traders are currently not required to hold a VARA license if they use their own funds to trade and do not offer their services to friends, family and/or third parties in the mass market (i.e. have no clients). Proprietary trading does not include variable asset (VA) activities involving the purchase and sale of variable assets with third parties using own funds at the initiative of the third party.
  2. Based on the above definition, proprietary traders – those with cumulative 30-day rolling trading volume exceeding $5 million – must register with VARA and be regulated regardless of whether they are conducting it as a business.

1. You need to apply for this type of advertisement through the Central Government Advertising System managed by Dubai Municipality.

2. You can apply for a license under the “Virtual Asset Activities” category.

3. You will need to confirm compliance with the Virtual Asset Regulatory Authority (VARA) marketing regulations and guidelines (link below).

4. VARA reminds all relevant parties to confirm their compliance with VARA’s marketing regulations and guidelines on the Dubai Government Content Approval System.

5. Failure to comply with VARA’s marketing regulations and guidelines may result in severe penalties, including large fines/penalties and may even lead to entity closure.

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