Asia & Middle East · AE
Dubai / VARA
Dubai's Virtual Assets Regulatory Authority (VARA) licenses and supervises virtual asset activities across Dubai, including its free zones other than the DIFC.
At a glance
- Status
- Emirate-level regime within the UAE
- Region
- Asia & Middle East
- Regulated sectors
- Crypto
- Authorities
- VARA · DFSA
- Licensing routes
- 2
- See also
- United Arab Emirates
Overview
The framework
VARA was established in 2022 as the dedicated regulator for virtual assets in Dubai. Its jurisdiction covers mainland Dubai and Dubai's free zones, with the exception of the Dubai International Financial Centre (DIFC), where the DFSA regulates financial services, including activities involving crypto tokens.
Licences are activity-based: advisory, broker-dealer, custody, exchange, lending and borrowing, management and investment, and transfer and settlement services are licensed separately, alongside rules on virtual asset issuance and marketing.
Authorities
Who regulates what
- Virtual Assets Regulatory Authority (VARA)
- Licensing and supervision of virtual asset activities in Dubai, outside the DIFC.
- Dubai Financial Services Authority (DFSA)
- Financial services in the DIFC, including crypto token activities.
Regimes
Licensing routes
VASP licence (activity-based)
A separate licence for each regulated virtual asset activity, such as exchange, broker-dealer or custody services.
Sectors: Crypto
Virtual asset issuance
Rules for issuing virtual assets in or from Dubai.
Sectors: Crypto
Applications and regulator engagement for these routes are handled by our Regulatory & Licensing practice.
Considerations
What to weigh up
- Choose between VARA and the DIFC based on clients, products and the legal system you need.
- Marketing of virtual assets to people in Dubai is regulated, including by firms licensed elsewhere.
- Local substance and resident management are expected.
This overview is general information, summarised at a high level. Requirements change and depend on the specific activity; seek advice on your circumstances before acting.
Industries
Relevant industries
Across jurisdictions
Cross-jurisdiction capabilities
Services we support across the jurisdictions in our directory, described once on their own pages. How each is delivered depends on the local requirements that apply; where local qualification is required, we coordinate locally qualified counsel.
- Privacy & Data ProtectionPrivacy compliance and GDPR programmes, notices and DPAs, DPIAs, data mapping and ROPA, transfers, audits and breach response.
- AML & Financial Crime ComplianceAML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.
- IP Registration & ProtectionTrademark and patent registration and protection, copyright protection, domain name disputes, portfolio support and IP agreements.
- Legal OpinionsRegulatory, business model, perimeter, payment, gaming, crypto-asset and cross-border opinions for banks, partners and investors.
- Bank Account OpeningSupport with corporate and operational accounts at banks and EMIs, prepared for how their compliance teams assess high-risk businesses.
- Merchant Account / Acquiring SetupSupport with merchant account applications and acquiring setup at acquirers and PSPs, including for high-risk merchant categories.
Support
How we support businesses in Dubai / VARA
- Regulatory & Licensing01Strategy, applications and regulator engagement for the crypto routes listed above.
- Corporate Structuring02Group architecture, incorporation, substance and governance built around your licences, banking and investors.
- Market Entry & Regulatory Strategy10Market prioritisation, regulatory roadmaps and launch readiness for businesses expanding into new jurisdictions.
Discuss your matter with a senior advisor.
Share a few details about your business and plans. We will come back to arrange a confidential initial conversation.