The Virtual Assets Regulatory Authority (VARA) as part of its enforcement program has fined as well as issued cease and desist orders 7 VASP entities for operating without a license and for breaching marketing regulations. The fines reach up to $27,000 depending on severity of violation.

VARA has asked the public to avoid engaging with unlicensed VASP firms because this exposes them to significant financial and reputational risk.

The VARA message, clearly stated, “Only firms licensed by VARA are authorized to provide virtual asset services in/from Dubai, and the Authority remains steadfast in its commitment to protect consumers and investors, and to preserve market integrity. ”

The Regulatory Affairs and Enforcement at VARA also noted, “Our priority is to ensure that Dubai’s virtual assets ecosystem remains secure for consumers and investors while being a progressive environment for compliant entities. Market enforcement actions send a reinforcing message: VARA will not tolerate any attempts to operate without appropriate licenses, nor will we allow unauthorized marketing of virtual asset activities. Our marketing regulations further emphasize Dubai’s commitment to ensuring transparency and always protecting stakeholder interests.” 

The 7 un-named VASP has been asked to cease their activities and stop marketing or advertising their virtual asset services.


Fines issued in this round range from AED 50,000 ($13,000) to AED 100,000 ($27,000) per entity, depending on the nature and severity of the specific instance of such violation.

Few weeks prior the regulator published its marketing regulations which covers not only Dubai but the entire UAE and GCC region.

The Dubai Financial Services Authority (DFSA) the regulatory arm of DIFC ( Dubai International Financial Center) has amended its crypto token regime. These changes stem from the proposals outlined in Consultation Paper 153 – Updates to the Crypto Token regime published in January 2024.

According to the press release, this marks a significant step in refining and advancing the regulatory environment for Crypto Tokens in the Dubai International Financial Centre (DIFC).

Amendments are related to the following areas, funds, custody, recognition of crypto tokens and financial crime

In terms of funds DFSRA now allows the offering of units of external and foreign funds investing in recognized crypto tokens, as well as the ability for domestic qualified investor funds to invest in unrecognized crypto tokens. Minimum individual investment in fund is $50,000. The Fund’s investment in Crypto Tokens is limited to Recognized Crypto Tokens and does not exceed 20% of the gross asset value of the Fund.

Firms can offer custodial and staking services as per the amendment but they cannot offer lending services. Cited in the document, ” An Authorized Firm must not offer or provide any facility or service that allows a Client to lend a Crypto Token to the Authorized Firm or to another person unless it is reasonably satisfied that:. (2) The restriction in (1) does not apply to: (a) an Authorized Firm that is authorized to Provide Custody, if: (i) the Crypto Token is not a Prohibited Token; (ii) the Authorized Firm is reasonably satisfied that: (a)(A) the Client is a Professional Client or Market Counterparty; and (b)(B) the lending is solely for the purpose of staking.; and (iii) the requirements in (3) have been met”

An Authorized Firm must be able to demonstrate to the DFSA’s satisfaction the grounds upon which the Authorized Firm considers the Third Party Agent or a non DIFC custodian to be suitable to hold Safe Custody Investments or Safe Custody Crypto Tokens.

In addition DFSA has replaced its previous Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML) – (AML/VER25/05-24) is repealed and has been replaced by Appendix 1 to this instrument and may be identified by the following reference – (AML/VER26/06-24). VASPs will have to comply with Federal Cabinet Resolution No. 10 of 2019 requirements under Federal AML legislation to Virtual Asset Service Providers (VASPs), in addition to Financial Institutions and DNFBPs. The DFSA’s AML regime applies in addition to the Federal AML legislation.

In terms of NFTs and utility tokens, the DFSA has excluded a Non-Fungible Token (NFT) and a Utility Token from its Crypto Token definition where such a Token meets specified criteria. However The DFSA has prescribed in AML Rule 3.2.1 that a person who carries on the business or profession of issuing or providing services related to a NFT or Utility Token is a DNFBP. An exclusion applies, in the case of an issuer, if the value of each NFT or Utility Token issued is less than $15,000 and, in the case of a service provider, if the service is IT support or advice to an issuer.

VASPs will have to adhere to AML requirements of the government of the U.A.E. or any government departments in the U.A.E.; the Central Bank of the U.A.E.; the FIU; the National Anti-Money Laundering and Combating Financing of Terrorism And Financing of Illegal Organizations Committee (NAMLCFTC); FATF; U.A.E. enforcement agencies; and the DFSA.

DFSA also recognized stablecoins which it called Fiat crypto tokens. DFSA does not consider privacy tokens or algorithmic tokens as recognized.

As noted, ” if Fiat Crypto Token, all of the requirements are met in respect of that Fiat Crypto Token including the matters referred to the regulatory status of the Crypto Token in other jurisdictions, including whether it has been assessed or approved for use by a Regulator in another Recognized Jurisdiction; whether there is adequate transparency relating to the Crypto Token, including sufficient detail about its purpose, protocols, consensus mechanism, governance arrangements, founders, key persons, miners and significant holders; the size, liquidity and volatility of the market for the Crypto Token globally; the adequacy and suitability of the technology used in connection with the Crypto Token and whether risks associated with the Crypto Token are adequately mitigated, including risks relating to governance, legal and regulatory issues, cybersecurity, money laundering, market abuse and other financial crime.

These changes are based on recent market developments, recommendations from international standard-setters and the DFSA’s supervisory experience.

Over the past two years, the DFSA has engaged with over 100 firms looking to be licensed, gaining valuable insights into the market dynamics and regulatory needs.

Ian Johnston, Chief Executive of the DFSA, said: “Our objective with the Crypto Token regime is to foster innovation in a responsible and transparent manner while ensuring we meet our regulatory objectives. At the DFSA, we have taken a balanced approach in the development of this regime and remain committed to evolving it in line with global best practices and standards.”

Noteworthy is that the amendments did not cover insurance which was mentioned in January in the consultation paper.

HexTrust, a digital asset custodian, under the UAE entity name of HT Market MENA, has been granted a VASP license from Dubai’s Virtual Asset Regulatory Authority (VARA) that will allow it to offer crypto brokerage services allowing it to serve both institutional and retail clients, pending that all requirements are fulfilled.

This is the second VASP license that HexTrust receives from VARA. It was previously awarded a crypto custodial license back in November 2023.

Hex Trust’s Dubai office was established in June 2022, and is led by Regional MENA Director, Filippo Buzzi.

On receiving the first license for digital asset custody services Buzzi stated, “It is exciting for us to become one of the first virtual asset companies to receive this operating license in Dubai,” said Filippo Buzzi, Hex Trust’s Regional Director MENA. “Hex Trust is fully committed to expanding into the Middle East and sees enormous potential for digital asset growth given the progressive regulations, welcoming governments, and thriving crypto ecosystem in the region.”

With this license Hex Trust will not only be able to hold crypto for its clients but also allow trading.

To date Dubai’s VARA has awarded 18 VASP licenses with the latest being Binance and WadzPay.

Moreover, there are more licenses on the way with Liminal Custody Solutions Dubai entity, “First Answer Custody FZE”, both providers of digital asset custody and wallet solutions, securing an initial approval from Dubai’s virtual asset regulatory authority (VARA).

Prior to that NorthStake a firm which offers safe, compliant and secure investment in Digital Assets for institutional investors as well as crypto staking and trading services applied and received a preliminary approval for a license from Dubai’s virtual asset regulatory authority (VARA) for a license.

During the Paris Blockchain Week, at the Global regulatory Landscape Panel session, Mathew White, CEO of Dubai’s VARA (Virtual Asset Regulatory Authority) discussed the cost of compliance for smaller crypto and Blockchain firms and the solution he is proposing where big players sponsor the cost of compliance for smaller ones.

White in his contribution during the panel made several points with regards to how he views VARA’s regulatory standpoint.

Firstly, VARA wants to regulate without damaging the presence of nearly 2000 Web3 and crypto companies already present in Dubai UAE. He states, “We seek to set a regulation that we feel anybody can be part of and is not exclusive by nature. We engage with the industry, governments, and continue to do that. While it is still not perfect, there are a number of things we are looking into to make the regime fit for everybody, one of which is how we deal with cost of compliance for small entities.”

According to White, compliance is a costly exercise and not many players have the resources to go and get regulated. His proposal is “looking towards a structure where larger market participants host smaller ones, where the cost of compliance can be borne by the large players.” He adds, “We are on this journey of allowing innovation whilst being able to regulate it.”

White explains that two years ago when he was part of the team building VARA, the Dubai government decided as part of their economic diversification project to prioritize technology and in specific virtual assets.

VARA was established to be able to position Dubai as a hub with financial stability and investor protection in mind.

When the topic of self-regulation through technology came up White acknowledge that he believes that this will one day be possible. He also stated he would be looking into piloting this idea at VARA.

He stated, “No doubt some point in the future it will be available. For the short to medium there will be regulation and it will be significant.”

Earlier this week, Crypto.com became the first international crypto exchange to receive a full license from VARA, while OKX is still awaiting final requirements to receive its full VASP operational license.

As the woes pack up on Binance crypto exchange, first with the guilty plea from CZ, and then Ronaldo being sued because he promoted Binance products, the Dubai Virtual asset regulator VARA has made a statement that it is continuing to asses and monitor Binance activities to strict regulatory requirements, rigorous KYC and due diligence.

As per VARA, Binance FZE crypto exchange currently only holds a Minimum Viable Product [MVP] Operational License with VARA, which allows them access to a restricted client base. As such to date, Binance have on boarded approximately 180 qualified investors and institutional clients.

VARA notes that it  cannot comment on regulatory and enforcement actions taken on business conducted in other jurisdictions, but does assure, “ We have been, and will continue to be, closely monitoring ongoing developments and specifically how they relate to Binance FZE operations in accordance with our commitment to uphold market integrity, consumer protection, and the security of the domestic ecosystem.”

Binance while being one of the first to apply for a license in the UAE, has been late in receiving a license while others such as M2 in Abu Dhabi, RAIN crypto broker, CoinMENA, Fasset,  and many others have been able to become fully licensed.

It seems that Richard Teng, the new CEO of Binance will have a lot on his plate in the coming months.

The Abu Dhabi financial free zone hub, ADGM (Abu Dhabi Global Market) and its regulatory body the FSRA (Financial Services regulatory Authority) have published their business plan for 2024 which outlines introducing DeFi regulations as well as amendments to its virtual assets regulatory framework.

ADGM which announced its virtual assets framework back in 2018 has since then been growing its framework most recently announcing its DLT Foundation regulations that would allow the issuance of governance tokens.

But more interestingly in its newly published business plan for 2024, the ADGM FSRA states, they are developing a framework for DeFi activities in 2024. ADGM business plan states, “The current focus for the FSRA has been on admitting decentralized finance (DeFi) solutions to the RegLab so that it can learn from the experiences of these companies and thereby take steps to develop a suitable regulatory framework for DeFi activities.”

Together, the RegLab and Digital Lab showcase how effective government led initiatives can advance the local ecosystem and be drivers of a business friendly environment.

ADGM and FSRA will also work to utilize AI (Artificial Intelligence)  and has engaged with several projects that leverage this technology, as well as to provide more interactive and chatstyle ‘Regulation as a Service.

In terms of its virtual assets framework while the FSRA has continued to refine and enhance its VA framework and in September 2022 published an update of the ‘Guiding Principles for the Financial Services Regulatory Authority’s Approach to Virtual Asset Regulation and Supervision’ on its approach to VA regulation and supervision, in 2024 the FSRA will review its regulatory framework for VAs to assess whether any enhancements are necessary. As stated in business plan,” This goes back to the FSRA’s experience gained from supervising VA businesses and the emergence of new VA regulatory frameworks introduced in relevant peer jurisdictions.”

Finally the FSRA is working with FinTech business models that can promote greater liquidity and financial inclusion in private capital markets using as well FSRA’s regulations that support the adoption of digital assets and tokenized securities which have enabled greater accessibility and transferability of private capital market investments.

So In 2024 the UAE and in particular Abu Dhabi will witness advancements in the virtual assets regulatory landscape, as well as introduction of DeFi regulations and more utilization of security tokens and digital assets for investments.

Those who have been following ADGM know that already Binance has gained a license, as has Bahrain headquartered RAIN exchange, and most recently IOTA announced it was launching its DLT Foundation from ADGM Abu Dhabi.

This article was first published in Cryptopolitan

Hex Trust, a digital asset custodian has announced that it has received a full Virtual Asset Service Provider (VASP) license from the Virtual Asset Regulatory Authority (VARA) in Dubai.

This follows the issuance of its MVP operational license in February 2023, which marks the final step in VARA’s licensing process, allowing Hex Trust to offer Virtual Assets Custodial Services to institutional clients and sophisticated investors in Dubai.

Hex Trust’s Dubai office was established in June 2022, and is led by Regional MENA Director, Filippo Buzzi.  “It is exciting for us to become one of the first virtual asset companies to receive this operating license in Dubai,” said Filippo Buzzi, Hex Trust’s Regional Director MENA. “Hex Trust is fully committed to expanding into the Middle East and sees enormous potential for digital asset growth given the progressive regulations, welcoming governments, and thriving crypto ecosystem in the region.”

“Hex Trust’s commitment to compliance and regulation has always been a priority. This focus has allowed us to be granted a full operating license in Dubai – one of the few companies to obtain this,” said Alessio Quaglini, Co-Founder and CEO of Hex Trust. “There is so much potential in the Emirate of Dubai. We’re excited to continue to scale our business in the region and make a positive contribution to the virtual asset ecosystem.”

The completion of VARA’s licensing process demonstrates Hex Trust’s commitment to provide a comprehensive, secure and compliant trading environment for digital asset investors in Dubai, and its dedication to help build the virtual asset ecosystem in the MENA region, which is fast becoming one of the world’s leading virtual asset hubs.

In July, Hex Trust received regulatory approval in France to provide digital asset custody services, introduced innovative AI-driven investment tools, and actively participated in global industry events. Hex Trust’s dedication to delivering 24/7 regulated digital asset support to its 200+ global institutional clients remains unwavering as the industry recovers from the bear market. Its resilient approach is a positive signal of confidence and underscores its commitment to building secure blockchain infrastructure and expanding its global reach as a fully-licensed digital asset custodian.

Komainu was the first to receive a digital assets custodial license by VARA.

Dubai’s Virtual Assets Regulatory Authority (VARA) announced that while more than 1,000 legacy firms have filed applications to register under Dubai’s unique regulatory framework, underscoring the city’s commitment to fostering a transparent and resilient virtual asset environment, these firms need to complete their applications in ten days, by November 17th 2023.

As per the press release, following the inception of the Authority by Law No. 4 of 2022 and the issuance of VARA regulations in February 2023, Dubai’s Virtual Assets sector, which includes specialist Virtual Asset Service Providers (VASPs) and traditional businesses involved in Virtual Asset activities, became a part of a regulated sector requiring all such legacy operators in the Emirate of Dubai to obtain licenses or registrations under VARA

Further to substantive outreach efforts facilitated in collaboration with the Department of Economy and Tourism (DET) and the Dubai Free Zone Council (DFZC) through 2023, VARA’s dedicated licensing team have successfully rolled out an accelerated domestic outreach program.

Dubai’s Virtual Assets Regulatory Authority (VARA) is advancing its engagement with the virtual asset market to evaluate compliance with its set regulations, emphasizing the obligatory licensing for all Virtual Asset Service Providers (VASPs) in the Emirate. Firms lagging in their application processes have until 17th November 2023 before enforcement mechanisms are due to be triggered by default.

As such VARA is calling on VASPs that have yet to submit the applications, have missed the notifications from their commercial licensing authorities, or have submitted incomplete forms to proactively get in touch, to avoid unintended regulatory consequences.

In recent months VARA has been issuing various market alerts. In its most recent alert it called to attention the media coverage regarding Bitay’s supposed entry into the UAE market, showcasing that unless they have secured approval or regulated by VARA or any other regulatory authority in the UAE. Prior to that it issued a notice with regards to Islamic Coin.

As per VARA, according to Cabinet Resolution No. 111/2022 advises the market to not engage with unregulated VASPs. VARA reaffirmed that Bitay is not regulated by VARA and has not sought to otherwise be registered with VARA.

This latest announcement by VARA comes after the UAE  National Anti-Money Laundering and Combating Financing of Terrorism and Financing of Illegal Organizations Committee (NAMLCFTC), in collaboration with UAE supervisors, has issued guidance on combating the use of unlicensed virtual asset service providers, which is prepared by the supervisory subcommittee.

The guidance, which aims to educate licensed financial institutions (LFIs) and the wider public sector on the risks associated with unlicensed virtual asset service providers, has been issued pursuant to the Decree Federal Law No.20 of 2018 on Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) and Illegal organizations. It aligns with the Financial Action Task Force (FATF) publication on updated guidance for a risk-based approach to virtual assets and virtual asset service providers.

The guidance provides the reporting entities, including LFIs, Designated Non-Financial Businesses and Professions (DNFBPs), and Licenced Virtual Asset Service Providers (VASPs), with a comprehensive roadmap to enhancing their governance and operational processes. It also highlights how to identify and address governance challenges and emerging risks, underlining the importance of compliance with regulatory obligations under AML legislation and the regulations, instructions, guidelines, notices, and rules issued by the Supervisory Authorities.

The guidance directs the reporting entities to consult the FATF Report on Red Flag Indicators of Money Laundering and Terrorist Financing regarding Virtual Assets. It specifically requires them to remain vigilant of the various fraudulent methods unlicensed VASPs adopt; continue to manage money laundering, financing of terrorism, and proliferation financing risks effectively; ensure emerging risks are factored into their business and customer risk assessments; and ensure due diligence is conducted to identify instances of forged documents and sanctions evasion.

As per the guidance, VASPs operating in the UAE without a valid license will be subject to civil and criminal penalties, including, but not limited to, financial sanctions against the entity, owners, and senior managers. Furthermore, reporting entities that demonstrate willful blindness in their dealings with unlicensed VASPs and have weak AML/CFT and Counter Proliferation Financing controls may be subject to enforcement action.

Khaled Mohamed Balama, Governor of the CBUAE and Chairman of the NAMLCFTC, said, “The new guidance on combating the use of unlicensed virtual asset service providers comes at a time when virtual assets become more accessible through digital channels. As our digital economy matures, our work on combating all kinds of financial crimes intensifies through raising awareness of their risks and emphasising the importance of compliance with relevant regulations and legislation to ensure the integrity of the UAE’s financial system.”

WadzPay has been granted “Initial Approval” by Dubai’s Virtual Assets Regulatory Authority (VARA), marking a pivotal step in Wad pay’s journey towards obtaining a Virtual Asset Service Provider (VASP) License for virtual asset services and activities.

“We are immensely honored to have received initial approval from VARA,” said Mr. Anish Jain, Founder and Group CEO of WadzPay. “This recognition reaffirms our commitment to delivering cutting-edge blockchain-based solutions that not only revolutionize but also adhere to the highest regulatory standards. We are grateful for the opportunity to contribute to the growth of the fintech ecosystem in the UAE.”

This Initial Approval is a key milestone and allows WadzPay to commence preparations for the provision of virtual asset services and activities under the VASP License for Transfer & Settlement and Broker/Dealer activities.

“Receiving VARA’s initial approval is a testament to our unwavering dedication to regulatory and compliance excellence,” said Mr. Khaled Moharem, President – MENA at WadzPay. “We’ve built a robust ecosystem that not only meets but exceeds industry standards, guaranteeing a safe and efficient gateway to virtual assets for users in the UAE. We’re poised to launch with strict adherence to VARA’s requirements, ushering in a new era of secure and seamless access to the world of virtual assets.”

While the initial approval is a pivotal achievement, WadzPay emphasizes that it is still in the process of working towards receiving the final approval from VARA and the VASP license. This progression marks a crucial step towards obtaining the necessary regulatory green light to fully operate within the UAE and bring its innovative products and solutions to life.

Prior to this WadzPay Founder Anish Jain had announced that WadzPay had made strides on the licensing front and are in the “final stages”. In addition he added that WPC token would be listed on a Tier1 regulated exchange in the Middle East.

WadzPay, an interoperable blockchain-based technology provider, had also launched the WadzPay 2.0 which it believes will redefine the landscape of virtual asset-based transactions. WadzPay 2.0 provides a unique new architecture primarily based on the Algorand blockchain with inbuilt support for several others such as Ethereum, Tron, Avalanche and several others to be added. WadzPay 2.0 construct is designed in line with evolving regulations and needs of banks, financial institutions, telcos and central banks.