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VARA activity-specific regulations
4
VARA rulebook registers
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Dubai
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The Virtual Assets Regulatory Authority (VARA) is Dubai's dedicated regulator for virtual asset service providers. Established in 2022 under Law No. 4, VARA has issued a layered regulatory framework — the VARA Rulebook — that applies to all VASPs operating in Dubai. For compliance teams at exchanges, custodians, broker-dealers, and virtual asset investment managers, navigating VARA's multi-document framework is a significant compliance burden. Lexara indexes the complete VARA regulatory corpus and makes it searchable — from the Company Regulations to each Activity-Specific Regulation — with AI Explorer for plain-English questions.
VARA's regulatory framework is structured across four documents that apply cumulatively to all licensed VASPs. Understanding the hierarchy is essential for compliance officers mapping obligations to their licence category.
Company Regulations — universal obligations for all VARA-licensed entities
Compliance and Risk Management Regulations — AML/CFT, risk framework, internal controls
Technology and Information Regulations — IT security, operational resilience, custody tech
Market Conduct Regulations — trading rules, market abuse, client protection
In addition to the universal rulebook, VARA has issued a dedicated Activity-Specific Regulation (ASR) for each of the seven licensed virtual asset activities. Each ASR contains operational requirements specific to that activity — capital, segregation, reporting, and conduct standards.
Advisory Services ASR — investment advice on virtual assets
Broker-Dealer Services ASR — buying/selling virtual assets for clients
Custody Services ASR — safekeeping and control of virtual assets
Exchange Services ASR — operating a virtual asset trading platform
Lending and Borrowing Services ASR — crypto lending products
Payment and Remittance Services ASR — VA payments and transfers
Management and Investment Services ASR — VA fund and portfolio management
VARA's Compliance and Risk Management Regulations impose detailed AML/CFT obligations on all licensed VASPs — including Travel Rule compliance, which is a VARA-specific requirement that many traditional compliance frameworks do not cover.
Customer Due Diligence to CBUAE AML standards
Travel Rule: originator and beneficiary information for VA transfers above AED 3,675
Suspicious Transaction Reports to UAE FIU (goAML system)
Annual AML risk assessment and MLRO appointment requirements
Sanctions screening for all customers and counterparties
Enhanced Due Diligence for high-risk customers and high-value transactions
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What is VARA in the UAE?
VARA (Virtual Assets Regulatory Authority) is Dubai's regulator for virtual asset service providers, established in 2022. It issues mandatory regulations for all VASPs operating in Dubai, covering exchange, custody, broker-dealer, advisory, lending, payments, and investment management services.
What activities does VARA regulate?
VARA regulates seven virtual asset activities: Advisory, Broker-Dealer, Custody, Exchange, Lending and Borrowing, Payment and Remittance, and Management and Investment Services. Each has a corresponding Activity-Specific Regulation with detailed requirements.
Is a VARA licence required to operate a crypto exchange in Dubai?
Yes. Any entity offering virtual asset exchange services to UAE residents from or within Dubai (excluding DIFC) must hold a VARA Exchange Services Licence. Operating without a licence is an offence under Dubai Law No. 4 of 2022.
Does VARA regulate DeFi and NFTs?
VARA's framework applies to virtual asset activities broadly. Certain DeFi and NFT activities may fall within regulated categories depending on how they are structured. VARA has indicated it will issue additional guidance on NFTs and decentralised protocols. Lexara indexes VARA's published guidance alongside the core Rulebook.
Is VARA the same as ADGM FSRA for crypto?
No. VARA regulates virtual asset businesses in Dubai (excluding DIFC). The ADGM FSRA regulates virtual assets within Abu Dhabi Global Market. Each requires a separate licence from the relevant authority.