As HE Omar Sultan Al Olama, Minister of State for Artificial Intelligence, Digital Economy and Remote Work Applications participated in the WEF session ‘Finding the right balance for crypto’  announcing that the UAE has not licensed a single crypto exchange, concurrently the Dubai based Virtual Asset Regulatory Authority (VARA)  affirmed this on its website in its latest announcement.

Al Olama told audiences at WEF, that the regulations in UAE are not light. There are extensive regulations at VARA. He affirmed, “ UAE has not issued a single licensed crypto exchange in UAE neither Binance nor FTX.” He explained that there is a four step process  and to date, “no one was able to onboard any customers even last week.”

Concurrently VARA stated on its website, “VARA has not granted any operating permits to date this is a four stage licensing process” VARA’s website explained, that the VARA regime is founded on the principles on enforcing responsible market participation backed by a future-proofed and responsive regulatory framework that remains technology agnostic; that collectively deliver socio-economic stability; robust consumer protection; and jurisdictional resilience.”

As such there are four stages to regulation at VARA, the first is Provisional permit; graduating to a 2-step [(2) Preparatory + (3) Operating] Minimum Viable Product (MVP) license; and culminating at the (4) Full Market Product (FMP) license.

The fourth stage takes into effect after regulations have been tested within the regime. As such according to VARA every Virtual Asset Service Provider [VASP] must go through all 4 stages in this current environment, wherein VARA expects to evaluate, observe, and only then authorize suitably qualified entities to undertake any market servicing activities under its licensing regime.

VARA then clarifies that at this stage the only licenses that have been issued are Stage Gate (1) Provisional or (2) MVP-Preparatory to enable VASPs to fulfill all pre-conditions, and undertake readiness steps establish offices, onboard employees with work visas, secure domestic bank account etc. prior to being in a position to undertake any market operations.

So VARA affirmed that no VARA licensee has, to date, been awarded an MVP-Operating permit.

Each VASP that is awarded an MVP license must comply with the [MVP License Conditions Document] issued by VARA, and strictly adhere to the licensing conditions outlined in the appended letter. One of the MVP conditions is that VA activities during this phase may only be provided to qualified and/or institutional investor segments.

Mass retail consumers are strictly prohibited until the Stage Gate (4) FMP license approval has been secured. [Virtual Assets and Related Activities Regulations 2023] will stipulate relevant licensing conditions and requirements.

VARA adds that when it publishes its full market regulation, it will enable borderless economic opportunity across the global VA industry, protecting investors and market participants, backed by active enforcement of all regulatory requirements beyond security and cross-border compliance including those pertaining to custody and segregation of client money; prudential requirements (viz. insurance and liquidity cover); FATF compliance, market manipulation and/or abuse prevention.

In terms of Virtual Assets Exchanges, VARA has awarded Binance (MVP Preparatory License Issued) while Bybit,, Equiti, GCEX, Huobi, and OKX have provisionary approval and started the process.

In terms of Virtual Assets Payment Services, Zamp has applied and have provisional approval. 

In terms of Virtual Assets Broker – Dealer services those who have applied and been granted provisional approval include BitOasis, CoinMENA, MidChains and Scallop

Virtual Assets Issuance Services include Calvin Cheng Web3.0 Holdings, Hike, Monstera, Prypto, Woonkly Labs, and Xfinite

While under Virtual Asset Custodians only Hex Trust (MVP Preparatory License Issued) and Komainu (MVP Preparatory License Issued)

Virtual Assets Management/ Investment Services: Amber Group, BRE Holdings, Brevan Howard, Fintonia Group, NineBlocks, NOIA Capital, TPS Capital and Q9 Capital have all been granted provisional approvals, first stage. 

Al Olama also noted at the WEF session that the job of a regulator is to try and be proactive and to protect people as much as possible whenever people adopt a technology. He states, “In UAE we have a young population so we need to ensure that we regulate fast because youth are early adopters. He added, “The UAE wants to protect talent since we aim to be the country with the highest per capital talent on earth.”

According to him there are other sides of crypto such as Web3 and UAE wants to attract Web3 and Blockchain talent. Blockchain is a technology of the future given that traceability cannot be removed. This according to H.E. Al Olama is a positive thing for the world as it is easier to trace someone who transacts through Bitcoin than through hard cash.”

He ascertained that regulators across the board need to work together. First bad actors should not be able to move from one place to another, and the same incidents should not be repeated tomorrow.

In terms of DeFi Al Olama believes it is is evolving and is least regulated. He states, “ We want to jump into each vertical on its own, the only issue we have is that while the UAE government can move fast  if we work with other governments as teams and we all scrutinize  every single vertical it is better as we cannot wait for next catastrophe.”

Bloomberg  just published a piece today November 27th 2022 that is rocking the UAE crypto ecosystem and is one of the most read pieces on Bloomberg as of now. As per the article roughly 4 percent of FTX’s global client base is in the UAE. This comes as no shock. LaraontheBlock had noted in an article on November 11th 2022 that VARA had suspended FTX’s crypto exchange license. The article at that time also noted that FTX MENA users brought in high revenues for FTX and was considered as the third biggest revenue region for FTX. 

Ben Bartenstein the author writes in the Bloomberg article, “Several crypto hedge funds recently launched in the UAE had dumped all of their client money on FTX, forcing an insane struggle to exit the platform before halting withdrawals to avert their own collapse, according to those familiar with the matter.”

The article also notes that roughly 4% of FTX’s global clients are based in the UAE, according to court filings in the company’s bankruptcy case, making it one of the ten most impacted jurisdictions.

The article adds that UAE officials have privately raised concerns about the pace of regulatory approvals that they may have moved too quickly and failed to identify the Three Arrows Capital and FTX blasts, people familiar with the matter said.

It goes on to state that Dubai’s VARA plans to announce its CEO in the coming weeks and intends to hold further consultations with key stakeholders before the end of the year. This information was provided by people familiar with the matter.

What the article fails to mention but was published in a separate piece recently on LaraontheBlock was that VARA is carrying out an investigation into the FTX impact on local UAE Market not limited to FTX MENA alone.

As VARA stated on its platform, ” VARA is following a developing matter involving the potential insolvency and alleged fraudulent behavior of an affiliate of a VASP licensed for participation in the MVP Phase. 

Dubai’s Virtual Asset regulatory Authority (VARA) has issued a statement with regards to FTX exchange. It reiterates that is has revoked the approval of FTX license as well as suspended its MVP License. As per the market notification, while FTX MENA had not commence local operations, VARA will be looking into the impact of FTX on domestic market exposure not limited to FTX MENA

As per the statement, On November 11, 2022, one hundred and thirty-four [134] entities related to, and including, FTX Trading Ltd., FTX Exchange FZE, and Alameda Research [Bahamas] Ltd. [collectively, the “Debtors”] filed a petition in the U.S. Bankruptcy Court for the District of Delaware for relief under Title 11 of the United States Code.

FTX Exchange FZE [FTX MENA], one of the aforementioned entities, had received approval from VARA for a Minimum Viable Product [MVP] licence on 15-Jul-2022 – the Approval was revoked as of 10-Nov-2022 and the Licence stands suspended in consequence.

FTX MENA was in the readiness preparatory phase and had not received VARA approval to commence operations, on board clients or service the market in the MVP Phase of the regulatory regime. Client Money Account with a domestic bank account had also not been secured – which is a pre-requisite for VARA to authorise any VASP operations in the UAE.

As such, the FTX MENA is confirmed to have no client exposure.

Further, in line with VARA’s principles of mitigating market and investor risk, all Virtual Asset Service Providers [VASPs] that have engaged with VARA to participate in Dubai’s regulated ecosystem, have been asked to provide disclosures to determine the severity of domestic market exposure, and contagion scale across the UAE. Details sought include:

·       Exposure to the FTX group of companies referenced in the 11-Nov-2022 bankruptcy filing, including holdings of the FTT token and any other assets

·       Nature and risk of the exposure; alongside the scale/magnitude; and impact/severity and manageability;

·       UAE residents that are impacted, including number of users and magnitude of exposure – both retail and institutional clients [not limited to FTX MENA];

Detailed action plans to mitigate the exposure highlighted above.

Following receipt of the information, VARA will publish a summary closure statement on impact within the VARA Regime. 

VARA also published the following statement, ” The MVP Phase is in its readiness preparatory stage to allow for approved licensees to fulfil all pre-conditions required to undertake MVP market operations within the VARA Regime. As such, no MVP licensees are permitted to provide any regulated services/activities to their specifically authorized market segment(s) until after VARA’s operationalization of the MVP Phase. VARA is following a developing matter involving the potential insolvency, and alleged fraudulent behavior of an affiliate of a Virtual Assets Service Provider (VASP) licensed for participation in the MVP Phase. The situation has been, and will continue to remain closely monitored for latest updates to ensure that timely and substantive actions are taken within the Emirate of Dubai to protect investors and all market participants, backed by active enforcement of regulatory requirements relating to custody and segregation of client money; insurance and liquidity cover; and in general all aspects pertaining to market abuse prevention.”

It is obvious that while FTX MENA had not commenced operations, there were a number of entities and individuals utilizing FTX international platform. This is well noted given that the MENA region was the third biggest revenue generator for FTX not in terms of number of customers but in terms of volume of trades.