A day after Dubai’s virtual asset regulatory authority issued a market notificiation stating that it had taken enforcement actions against BitOasis and advised investors and consumers that BitOasis’s MVP operational license is under review for not meeting mandated conditions, BitOasis replies back that this does not effect the services being offered to existing customers. 

BitOasis was supposed to satisfy certain requirements within 30-60 days of receiving their MVP operational license prior to being permitted to undertake any VARA regulated market activity. 

As such VARA is  exercising its authority to supervise and monitor compliance, assure fulfilment of prescribed conditions, impose remedial measures, and take necessary enforcement actions, including but not limited to holding BitOasis’ Licence status as non-operational.

In response to this BitOasis replied, “ BitOasis  ongoing work to fulfill select conditions associated with its Operational MVP License with respect to serving Institutional and Qualified Retail Investors. BitOasis is working closely with VARA on fulfilling the remaining conditions and is committed to providing a safe and secure service to its users.” 

BitOasis notes that the notification issued by Dubai’s VARA only covers institutional and qualified investors. BitOasis confirmed that it had not began offering thse services to these segments as they needed to fullfill all VARA mandated conditions under its Operational MVP license. 

As such according to the clarificiaiton by BitOasis, “This does not impact our ability to continue to provide broker dealer services to our existing retail users, although we undertake to not onboard any new clients until we have fully complied with VARA requirements.” 

BitOasis added that they are committed to remediate all outstanding post licensing conditions of their Operational MVP license as committed to the regulator, as well as working towards Full Market Product (FMP) licensing.  The clarification adds, “ We remain committed to securing a broker-dealer license, and operating a compliant, regulated platform in and from Dubai under VARA’s supervision. Transparency has always been a key value of our business – we will continue to update our community as we address these requirements prior to applying for an FMP license.” 

It s no surprise that global crypto exchanges are flocking to the UAE, first it was Binance, then Kraken which left, then crypto.com, coinbase, and now the second biggest global exchange OKX.

OKX announced unilaterally that it had received a minimal viable Preparatory license from Dubai’s virtual asset regulatory authority (VARA). In 2022 OKX had received its provisional license and opened offices at the Dubai World Trade Centre. 

In the announcement they stressed that the UAE is a key strategic growth and business hub for OKX global with the company planning ot hire 30 staff locals and senior management.

OKX also added that it plans to extend its nine-figure brand partnerships to the UAE with customer and fan-focused activations and activities.

As per the announcement, once licensed to be operational, OKX Middle East will be able to extend its approved suite of duly regulated virtual assets activities and will provide spot, derivatives, and fiat services, including USD and AED deposits, withdrawals and spot-pairs, to institutional and qualified retail customers.

OKX Global Chief Commercial Officer Lennix Lai said, “We’re thrilled to receive the MVP preparatory licence from VARA. Regulated entities are the future of digital assets and capital markets and Dubai and VARA have succeeded in creating a unique environment where VASPs can thrive. With the expansion into a new office this year, we are focused on hiring local staff and senior management. The MENA region has incredible potential as a centre of excellence for Web3 and virtual assets, we look forward to the opportunity to expand the already growing ecosystem across the region.”

OKX Chief Marketing Officer Haider Rafique  added “We’ve been waiting to enter the UAE and we want people here to experience our products first hand. We’re different – we do things in a measured and transparent manner. May was our seventh consecutive month of publishing our proof of reserves, making us the only crypto exchange globally with that commitment. This attitude is consistent with the brand partners who represent us, Manchester City Football Club, McLaren Racing, and the Tribeca Festival. We take our time, and do things the right way.”

But on VARA’s website OKX is not listed in its public register, while Crypto.com, Binance, and BitOasis are. This is despite the fact that both Crypto.com and Binance have the same license approval as OKX.

This is not the first crypto exchange or virtual asset service provider to unilaterally announce they have received a license yet have never been put on VARA’s public register. Examples include, AquanowMaskex crypto exchange, Fasset tokenized assets exchange, and many others.

The question that is puzzling is why? Why put some names and not others, why highlight some companies in VARA press releases, like for example BitOasis, Crypto.com, GCEX, Enjinstarter, Binance, Hextrust, , but not Maskex, OKX and many more?

It might seem to be a small discrepancy, but to those who look at the VARA website as a legitimate source for knowing the status of VASP entities regulated in Dubai, it is a significant slip-up or maybe not!

As an update to this article, OKX has now been listed on VARA’s registry page on its website, still waiting to see Maskex, Aquanow and others 

Over the past years and despite the continuous banning of crypto in Qatar by the Qatar Central Bank, crypto trading and investing in Qatar is flourishing reflected in various ways. 

The first reflection of the attractiveness of crypto trading in Qatar is the statement made by Qatar’s Ahli bank, at the end of May 2023. The bank warned customers against, trading, buying and selling virtual assets and currencies through accounts and banking services, citing the reasons as being associated with high risks.

Secondly Triple A report in January 2023 put Qatar’s crypto ownership at 0.9 percent of the population, around 24,000 people. Since then it could be the numbers have increased. Just over a year ago CoinMENA had announced that it was serving clients in Qatar. Even Bahrain’s RAIN crypto broker supports Qatar, as does UAE based BitOasis.

But the third and most significant reflection of the growth of crypto in Qatar is the recent MENA FATF report, where they mention that Qatar needs to work more on improving its risk understanding, implementation of TFS ( Targeted Financial Transactions) and NPO (Nonprofit organizations) preventive measures for virtual assets, and virtual asset service providers.

As mentioned in their report, “ Qatar has a very strong level of compliance with the FATF Standards, with only minor improvements needed in relation to risk understanding, implementation of TFS and NPO preventive measures, VAs and VASPs, wire transfers, transparency for legal persons and arrangements and cross-border movements of cash and BNIs.

So while Qatar has embraced blockchaindigital assets, and is studying the possibility of implementing CBDC, while shunning crypto, the population in Qatar seems to be moving forward with the crypto times.

Crypto.com, a global crypto exchange seems it will soon  become the second crypto exchange in Dubai UAE to receive MVP operational license after BitOasis.

VARA’s public register had listed CRO DAX Middle East better known as Crypto.com as having an MVP operational license authorized for specific activities and product types. As stated prior, Crypto.com is only authorized to serve qualified retail and institutional clients, but VARA website has since then removed it and now states it has an MVP preparatory license. 

Sources close to the matter state that this is a sign that an operational license is soon to come. This would make crypto.com the first global exchange to receive an MVP (Minimum Viable Product) operational license from VARA. 

This comes after the UAE Central Bank recently announced its AML (Anti Money Laundering) and FTC for financial institutions dealing with VASPs.

Binance has also yet to receive its operational license and still holds the status of MVP preparatory license.

More and more global crypto exchanges are seeking to set up regulated licenses in UAE.

As per Dubai VARA website, BitOasis, the crypto broker exchange has moved one step forward in its licensing process. It has become the first among VARA’s crypto broker dealers to receive MVP (Minimum Viable Product). operational license one step before the FMP ( Full Minimum Product) Operational License.  

CoinMENA, Scallops, and MidChains are still in the first stage as MVP provisional while GCEX has received an MVP preparatory license one step before MVP operational license.

BitOasis applied for VARA licensing in March 2022. At the time BitOasis had carried out crypto trades worth $4 billion. Ola Doudin Co-Founder and CEO of BitOasis has stated at the time, “  “We will continue to strive to offer our customers the most customized platform for their local needs in accordance with regulations that will best protect them both now and as the industry evolves.”

In April of 2021, BitOasis announced that it had been granted a a Financial Services Permission (FSP) from the Financial Services Regulatory Authority (FSRA) in the Abu Dhabi Global Market (ADGM) in the United Arab Emirates (UAE), but is still awaiting additional launch approvals as well.

BitOasis has raised a total of $30 million in funding from investors such as Alameda Research, Digital Currency Group, Global Founders Capital, Jump Capital, NXMH, Pantera Capital, Wamda Capital and others.

In October 2022 UAE based crypto exchange BitOasis, and MasterCard launched crypto card programs across the MENA region to facilitate day to day usage of cryptocurrencies at points of sale and ecommerce websites.

On Monday May 1st, Bitoasis in its official announcement and VARA made the following statements,

 Henson Orser, Chief Executive Office, VARA stated “We are pleased to welcome BitOasis to the MVP Programme phase. The VARA ecosystem aims to strike a balance between value creation, risk mitigation and enhanced investment opportunities with consumer protection at its core. BitOasis has demonstrated a strong commitment to operating with a firm bias for regulation throughout the licensing process. One of VARA’s founding principles is creating an equal opportunity regime for responsible VASPs and being able to onboard credible home-grown companies, like BitOasis, in addition to leading global platforms, allowing us to bring the shared learnings of our licensees to build the foundation for our global future economy.”

Ola Doudin, co-founder and CEO of BitOasis added, “We are extremely proud to receive VARA’s MVP Operational License. Becoming the first virtual asset trading platform in the MVP programme to attain an operating license is an important milestone for us and the Emirate of Dubai.”

 Samir Satchu, Senior Vice-President of Public Policy & Expansion at BitOasis noted, “Our commitment and ambition at BitOasis is to serve the GCC and MENA region through a network of regulated platforms and on the ground infrastructure. VARA’s MVP Operational License, as well as our in-principle approval in Bahrain, are important building blocks for that strategy. “

BitOasis is following in the footsteps of HexTrust crypto custodian who also received MVP operational license earlier this year.

VARA and UAE’s Security Commodities Authority both announced the commencement of licensing of already existing and new crypto entities. 

Article was updated on May 1st 2023 with quotes from VARA and BitOasis

It all started with the FTX downfall and then Binance’s Co-Founder and CEO call for crypto exchanges to carry out proof of reserves. Since then crypto exchanges such as Binance and crypto.com have provided wallets addresses tied to company wallets while Nansen blockchain analytics firm is creating a display of crypto exchange proof of reserves dashboard that currently includes Binance, crypto.com, OkX, Kucoin, Deribit, Bitfinex, Github, and others.

But what are locally homegrown crypto exchanges in MENA doing. Will they carry out proof of reserves, do they see it as the solution to bring trust back to crypto exchanges, and who has exposure to FTX?  

MENA Crypto Exchanges and Proof of Reserves

Bahrain based CoinMENA Talal Tabbaa and Dina Sama’an when asked by LaraontheBlock about if they will be doing proof of reserves stated, “This FTX news is a major setback for our industry and highlights the importance of regulation. This is why CoinMENA was established under the Central Bank of Bahrain, with a robust regulatory framework and compliance requirements. We go through regular audits and have to submit periodic reports to the regulators. More importantly, we keep our user funds in segregated accounts and we don’t offer leverage or margin which severely increases the risk profile of an exchange. We see crypto as a long-term investment and will continue to manage our risk prudently to build a sustainable and profitable business.”

Tabbaa adds, “CoinMENA is also reaching out to Nansen who is heading this effort globally to see the best way for it to be done.”

UAE regulated BitOasis CEO Ola Doudin states, “We believe that locally regulated platforms that follow industry best practices with proper oversight and supervision by their local regulators is the best way to ensure consumer protection and proper risk management practices.”

Vasja Zupan, President of UAE based Matrix Exchange in a reply to the question of whether they will do proof of reserves states, “We simply hold 1:1 client assets in our custody that is literally reconciled daily and regularly reported and checked by regulator and external auditors.”

Basil Askari Co-Founder of UAE MidChains has a similar reply, “In terms of proof of reserves we are already doing this on a daily basis with our regulator by providing daily client account reconciliations.”

Ola Doudin in her reply to this question stated, “BitOasis holds client assets in segregated client money accounts and custody environments. We’re an audited company that maintains the highest level of security and industry practices in storing and maintaining client assets one to one backed. We do not engage in any fractional reserve practices, proprietary trading, lending, and borrowing and we do not have an exchange token.”

Christopher Flinos, Chief Executive Officer of Hayvn crypto exchange in UAE “We already do proof of reserves. Our client’s crypto stays in segregated client wallets and our clients have always had access to their reserves. The firm in addition keeps shareholder funds in USD We hold no treasury in any coins not even stablecoins.”

Will Proof of reserves bring trust back to crypto exchanges?

Zupan believes that proof of reserves is totally useless without “proof of liabilities”. As he explains, “Proof of reserves alone should not bring trust back without 3rd party reviews and regulatory oversight over centralized services. I believe that CeFi needs a strong regulatory overview in combination with strong transparency and DeFi needs total transparency with independent reviews (not everyone can evaluate complex software and framework).”

Basil Askari co-founder of MidChains believes it is not enough to publish numbers. He explains, “Regulation and strict supervision by regulators on how client funds are used, is and has always been critical, as in TradeFi.”

Talal Tabbaa believes that the way crypto exchanges are carrying out proof of reserves at the moment is missing an important element. He explains, “In accounting when you provide information on your assets, you also provide information on your liabilities. Crypto exchanges need to do both proof of reserves and proof of liabilities preferably on a blockchain in real-time.”

Flinos agrees that with the current behavior of crypto exchange leadership trust is continuing to be damaged and what is need is strong regulation, control and corporate governance.

Exposure to FTX

In the past both CoinMENA and BitOasis had in their investment rounds received investment from FTX Ventures through Alameda Research. As such CoinMENA in a joint statement from both Talal Tabbaa and Dina Sam’an, Co-Founders, to LaraontheBlock clarified the following:  “FTX’s Investment arm Alameda Research invested $1 million in CoinMENA’s $9.5m seed funding round in 2021. All the funds were received prior to the close of the seed round. Their stake is less than 3% and has no voting rights. In light of the recent news, we have offered to buy back their minority stake.”

BitOasis also made a public blog post where it stated the following: “BitOasis confirms that it has no commercial relationship or exposure with Alameda Research (Alameda) or any other FTX entity. Accordingly, recent events at FTX and Alameda do not have any bearing on our business, or our ability to provide our customers with a safe and secure trading experience. In 2021, Alameda participated in BitOasis’ Series B financing round. As a result of its investment Alameda holds a 2.2% shareholding in BitOasis through Alameda Ventures Limited. Alameda is not represented (nor has it ever been) on BitOasis’ board of directors or on any governance forum or committee in any capacity. The shareholding is small and hence creates no exposure to our business.”

Matrix, Hayvn and MidChains founders confirm that they have zero exposure to FTX. Zupan stated, “We don’t have any exposure to FTX or any related party or similar protocols.” Al Askari as well confirmed, “Both our client funds and corporate assets are not exposed. We keep our (and our clients) funds in a safe boring 1:1 holding.” Flinos confirmed that they do not deal with unregulated counterparts.

Two crypto exchanges, RAIN in Bahrain and Veromex in UAE have not yet replied to the queries posed, if and when they do reply, their responses will be added.

Take Away

While up until now international exchanges have always looked more attractive because of their liquidity and the amount of crypto they list as well as their geographic coverage, it seems that those regulated in the region whether in UAE or Bahrain are looking more attractive because of their adherence to strong regulatory bodies.

A lot of news is coming out that international exchanges undertaking so called proof of reserves are not being transparent. For example Crypto.com’s cold storage revealed a suspicious transfer of 320,000 Ether worth $404 million, to Gate.io.  Kris Marszalek, CEO of Crypto.com assured traders that the transfer was accidental; funds were to be moved to a new cold storage address. Experts allege that the transfer helped Gate.io show its proof of reserves of user funds shortly after the transfer. Even more so it seems that 20 percent of crypto.com reserves are in Meme Token SHBB.

This also happened with Huobi. It was noted that after Huobi released the asset snapshot of the asset reserve, 10,000 ETH was transferred from Huobi to Binance and OkX deposit wallets. (Etherscan.io)

Binance CEO CZ also made an interesting tweet today November 13th 2022 where he says Binance is not just a CEX (Centralized Exchange). This comes as the crypto mood globally moves towards DEX (Decentralized Exchanges). In his tweet he gives advice on how to store crypto in your own wallet, and refers to trustwallet while saying that Binance is not just a CEX but provides other options.

In the end, the future is in decentralized exchanges, smart contracts, and blockchain databases for proof of reserves such as Etherscan.io and others. Crypto was never the culprit, it was molding crypto into a traditional financial sector that was.

UAE based crypto exchange BitOasis, and MasterCard are launching crypto card programs across the MENA region to facilitate day to day usage of cryptocurrencies at points of sale and ecommerce website.

BitOasis customers will be able to convert their cryptocurrency holdings to fiat currency allowing the consumer to easily shop and pay at more than 90 million merchant locations globally. The first BitOasis cards are expected to launch in early 2023 in markets with regulatory approvals.

BitOasis customers, who can also access a range of MasterCard benefits, will be issued with virtual and physical BitOasis cards through a simple and compliant digital on boarding experience via the BitOasis app, allowing them to transact seamlessly physically and online.

BitOasis customer transactions will be enabled to take place in Fiat currency, thereby adding consumer protection – such as provisions for dispute resolution and refunds – which doesn’t exist today when paying with a digital asset. The partnership will address these pain points and further drive customer awareness and crypto adoption in the region. 

Amnah Ajmal, Executive Vice President Market Development, EEMEA, MasterCard, said: “Changes in consumer demand, as they look for new, fast and flexible digital experiences, are fueling an increase in the adoption of emerging payment technologies. With this comes a greater expectation for businesses to provide multiple ways to shop and pay. Through our collaboration with BitOasis, one of the most innovative crypto platforms in MENA, we enable the consumer experience to be seamless by using their cryptocurrencies in a safe and secure environment.”

 Ola Doudin, CEO and co-founder, BitOasis, stated,  “We continue to witness sustained demand amongst our customers for crypto to be integrated into, and relevant, for their daily lives.  Research tells us that 47% of the Middle East population now believe crypto is the future of money. As the largest crypto platform built for the GCC and MENA region, we are delighted to partner with Mastercard to enable BitOasis customers to benefit from the convenience of linking their BitOasis wallets to their BitOasis Mastercard Crypto Cards for use across Mastercard’s global merchant network. Our mission at BitOasis is to enable a new digital financial system that is transparent, inclusive, regulated, and relevant on a daily basis, whilst providing even greater safety and security for cryptocurrency payments. Today’s partnership helps us deliver against our mission”.

It seems BitOasis beat Binance to it. In August Richard Teng head of Binance MENA had stated that they would be close to launching crypto cards with MasterCard in MENA. Since then no announcement. But here is BitOasis all partnered up and ready to go.

800,000 Saudi’s used digital currencies in 2021 with the value of virtual asset transactions in Saudi at around 20 billion USD and this is expected to grow five times over the next five years. The information was shared by Ali AlObaid, Managing Director of BitOasis crypto exchange, to Arab News

In the article he states, “We believe that this can grow by five times over the next five years. Last year, KSA probably represented 15 percent of Gulf Cooperation Council and Middle East and North Africa activity.”

He added that around 4 percent of adult population in MENA will have invested in crypto by the end of 2022. While in the USA 20 percent of adults have invested in crypto.

BitOasis user base in KSA is primarily millennials, 25-34 year old’s, with 30 percent of those trading on BitOasis between the ages of 35-44 years.

In a YouGov survey recently it noted that 1.8 percent of Saudi Arabian residents currently trade in cryptocurrencies. Yet it is Morocco that tops crypto ownership as per a TripleA report, followed by Egypt, UAE, and then KSA.

The report noted that in 2021 3.9 percent or 300 million people were crypto users globally with 18,000 businesses accepting crypto payments.