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 

UAE money exchange company, Ferg ( Foreign Exchange and Remittance Group) CEO has stated that the company as well as other money xchanges will start to accept crypto after Central Bank regulations are out sometime at the end of 2023 or early 2024. 

Adeeb Ahamed, Vice Chairmen of Ferg and managing director of LuLu exchange stated, “We are constantly in conversation with the Central Bank and waiting for the regulations. The Central Bank understands the use case of cryptos – CDBC (central bank digital currency). Cryptos is something that has definitely been taken up by the world. It needs to be part of the payment ecosystem. We are very sure that with the regulations coming out by the Central Bank, we will also start accepting.”

Ahamed expects regulations around digital currency are likely to come out later this year or early next year.

These statements were made on the sidelines of Ferg’s Techno meet 23 in Dubai UAE.

Ahamed added that exchange houses could no longer be content by being traditional models of doing business. “In the fast era of digitalisation, it is very important that we find partners that make the journey of customers much easier.

Web3 tokenized indices investment startup, nealthy, which recently raised $1.3 million, has set up its headquarters in Dubai UAE.

nealthy provides index tokens that replicate the structure of classic exchange-traded funds (ETFs). By storing multiple digital assets in on-chain vaults, building a diversified portfolio, and issuing an underlying indicator token. The first token will be called $nNFTS (which retains its real value through a peg to recognized blue-chip NFTs), nealthy is lowering the barriers to entry and opening the floodgates of digital asset investment to people around the world.

The leadership team of CEO Ludwig Schroedl, CTO Zied Said, and CMO Tim Pascual said that Dubai-based operations would help expand to a crypto-friendly region renowned for its forward-looking strategies. “We are thrilled to announce our move to new corporate headquarters in Dubai. From the standpoint of Dubai’s robust investment market to its renown as a hub for innovation, tourism, collectibles, luxury, and more, operating from Dubai will give nealthy access to the customers, investors, partners, and collaborators needed to bring nealthy’s performant solutions to as wide a user base as possible. 

We are excited about the next stage of our journey and cannot wait to power ahead with new releases and developments for our clients, partners, and investors,” said Ludwig Schroedl.

The UAE virtual asset regulatory authority has published its new virtual asset rulebook for, the virtual assets transfer,  and settlement service.  

This comes after the Central Bank of UAE published its guidelines for AML CFT compliance for financial institutions in relations to VASPs in the UAE.

As published in the rulebook, VASPs providing VA Transfer and Settlement Services must comply with all applicable legal and regulatory requirements issued by the Central Bank of UAE which apply to the VASP, which pertain to the end-to-end enablement of payments, remittances and/or other related services as may be amended from time to time.

As per the transfer and settlement service rulebook document, VASPs providing VA Transfer and Settlement Services must ensure that they comply with all legal and regulatory requirements for such services, inside and outside of the UAE. VASPs must ensure at all times that any transmission or transfer, and/or settlement being undertaken is permissible and can be facilitated through, and concluded in, all jurisdictions that are relevant to that transmission or transfer, and/or settlement.

The VASPs also have to comply with the compliance and risk management rulebook. VASPs providing VA Transfer and Settlement Services must comply with all requirements with respect to AML/CFT contained in that Rulebook, including but not limited to FATF-specific compliance requirements such as the Travel Rule.

The VASPs are liable to clients for the correct transmission, transfer or settlement of virtual assets to recipients whether from VASP wallet or VA wallet. VASPs are also responsible for the functioning of VA wallets or accounts of its clients for the purposes of receiving Virtual Assets, as well as providing all routing information that is necessary for a transmission or transfer, and/or settlement to be completed when requested by the sender’s VASP.

In addition VASPs must maintain records of all client instructions for a period of eight [8] years.

With this Dubai and the UAE have now finalized the major crypto and virtual asset rulesbooks, allowing VASPs to offer  transfers, and settlements for virtual assets. 

UAE based Sabre56 a hosting provider and digital asset mining consultancy, has signed a hosting deal with U.S. based GEM Mining, an institutional-grade Bitcoin (BTC) mining company.

As per the agreement, Sabre56 will initially host 4, 510 of GEM mining’s BTC miners in Sabre56’s new hosting facilities in Wyoming in USA.

As per the announcement, half of the miners will come online in May, and the remaining miners in June.

The deal follows Sabre56’s February announcement of its US$35 million funding agreements to build 150MW of Tier 0 data centers to support blockchain infrastructure.

The Company is rapidly transitioning from consulting on mining projects to constructing and hosting its own facilities, and today’s news is the first among the waitlist of miners ready to take hosting services in the new and future facilities that are currently under construction.

Phil Harvey, CEO of Sabre56, stated, “We are excited to welcome our new partner – GEM Mining. Our two companies are united in our vision for the mining industry, our core values of how to achieve it, and the pursuit of excellence taught in the military.

John S. Warren, CEO of GEM Mining, added, “GEM Mining is built for robust, long-term growth to drive the digital asset mining industry towards maturity. As the United States consolidates its status as the Bitcoin mining capital of the world we have – in Sabre56 – found a partner operating in the same ‘cut-to-the-chase’ way. We are delighted to place our machines with a hosting provider of such outstanding capabilities.”

In the MENA region, Sabre56 has delivered MWs of computing power.

Laraontheblock speaking to Phil Harvey asked if they had intentions to develop digital asset hosting facilities in UAE after the entrance of Marathon Digital. His response, “For almost a decade now, the UAE has been at the forefront of cryptocurrency innovation – welcoming the sector like few other places. The most recent example is the introduction of the UAE’s VARA regulation, which puts it comfortably ahead of Europe and the United States in terms of regulatory clarity.”

He added, “Marathon Digital’s move to expand mining operations to the UAE is an interesting entry, and we are closely watching the progress of their Masdar City immersion Bitcoin-mining facility. Compared to more temperate geographies, the GCC’s arid and hot climate poses a formidable obstacle to successful and efficient mining operations.”

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.

World Economic Forum report entitled “  Pathways to the Regulation of Crypto-Assets”  says UAE crypto asset regulatory framework is an agile one,  defining it as flexible, iterative and proactive which is beneficial because it is flexible, appreciate market maturity and ecosystem development.

According to the WEF report, regulators that fall under this model include the Swiss Financial Market Supervisory Authority. FINMA’s token classification prescribes three simple categories: payment tokens, utility tokens and asset tokens. The framework acknowledges hybrid tokens and that a token’s classification may change over time. Following the first classification, FINMA later also published further guidance in

Also included as per the report are the regulatory sandboxes in the EU and India in addition to the UAE. 

Instead of prescribing and enforcing rules, agile regulation adopts a responsive, iterative approach, acknowledging that policy and regulatory development is no longer limited to governments but is increasingly a multi-stakeholder effort. Yet it also faces challenges that include the need for coordination and collaboration being as well plagued with uncertainty. 

Regulatory sandboxes, guidance and regulators’ no-objection letters are all forms of agile regulation that enable the testing of new types of solutions, iterating policy frameworks based on ecosystem evolution and industry needs.

The report sets out to understand and highlight the needs and challenges in developing a global approach to crypto-asset regulation. In doing so, it delves into the various regulatory approaches being adopted by different jurisdictions.

The report developed rankings for each regulatory framework. The rankings covered four areas when analyzing regulatory frameworks and found that the agile regulatory framework is best at promoting innovation. Agile regulatory framework ranks in the middle ground for providing certainty for businesses, addressing data gaps and enforcement effectiveness.

The report finds for example that Regulation by enforcement which the USA falls under is weak in all the above mentioned areas except for enforcement effectiveness.

As per the report the UAE has not only initiated a license regime for crypto assets, but has also carried out consultation for decentralized applications such as DeFi, and DAOs.

In addition the report mentions that few jurisdictions have chosen to address the difficulty of classifying tokens, partially relying instead on the functionality enabled by the token.

For example, Liechtenstein has chosen not to rely solely on classifications but to introduce the token as such as an element in Liechtenstein Law, meaning that the right or asset represented in the token triggers the application of special laws (the so-called “token container model”). This means that the tokenization as such has no legal effect: if a financial instrument is tokenized, the financial market laws are applicable if the activity is regulated, too; if a commodity is tokenized, the laws for commodity trading might be applicable; and so on. For new instruments, such as utility coins and virtual currencies, a new regulation has to be defined.

While in the UAE, the Virtual Assets Regulatory Authority in Dubai has put forth a framework that is underpinned by overarching regulations and compulsory rulebooks, segregating activities-based rulebooks to rapidly account for novel products, emerging technologies, and new business models that require regulatory capture.

The paper’s findings reinforce the urgent need for policymakers and regulators to collaborate with industry and users to realize the benefits while addressing the risks involved.

Enforcement is still weak globally. For example in the context of AML supervision of crypto-assets, a Bank for International Settlements (BIS) 2021 survey found that oversight remained nascent globally. As stated, “Although many are at different stages, with some countries still finalizing applicable law and policy and a small portion engaging in active supervision, by and large effective enforcement measures remain a work in progress. The result is a complex tapestry of enforcement trends as well as enforcement risks posed by the cross-jurisdictional influence of crypto-assets.”

Even when it comes to the FATF travel rule implementations are also limited. As noted in FATF’s June 2022 targeted update report, interoperability across technical solutions and across jurisdictions is still lacking.

WEF report as such notes that such fragmented enforcement techniques will pose a challenge to the supervision and monitoring of crypto-assets against regulations in the short term and may take many years to standardize.

The report recommends promoting a harmonized understanding of taxonomy/classification of crypto assets and activities, set out best practices and baseline regulatory standards for achieving the desired regulatory outcomes and encourage passportability of entities and data sharing.

Building on this foundational paper, the World Economic Forum’s Blockchain and Digital Assets team will launch an initiative focused on evaluating the outcomes of different regional approaches to regulation. This effort will convene public- and private-sector leaders to reveal first-hand learning’s and the unintended consequences.

But not everyone shares the WEF reports belief that International crypto regulations and standards are possible.  During the Qatar Economic Forum this week, Peter Smith Co-Founder and CEO of Blockchain.com rejected claims of a “United Nations” of crypto as inconceivable. He stated, “A global system to regulate cryptocurrency is unlikely to exist.”

However, the Blockchain chief recalled the recent EU passing of the world’s first comprehensive package as a step forward in cautiously regulating the cryptocurrency industry. In addition, Smith told Bloomberg that regulators that express optimistic calls to crypto would promote development for the industry.

So whether a global harmonic set of crypto assets regulations are formulated or whether regional and national countries work to build their own, the growth of crypto assets cannot be curved by regulators. 

Japanese Nomura Bank’s, Komainu, a regulated digital asset custody provider, has received an MVP (Minimum Viable Product) operational license from Dubai’s Virtual Asset Regulatory Authority (VARA). This is one step from receiving the full operational license. This also follows HexTrust another digital asset custodian who received the license prior. Under the license Komainu will be able to offer both custodial and staking services.

Komainu had received provisional regulatory approval from VARA in July 2022 allowing it to commence operational readiness even as the application goes through the warranted due diligence.

Komainu acts as key gatekeeper to institutions gaining exposure to the digital asset industry with the provision of secure and regulated digital asset custody services for blockchain and beyond. Over the years, Komainu has established itself as one of the leading digital asset custody providers for institutional clients, providing the same safeguards and protections investors are accustomed to in traditional finance. 

Komainu is the first hybrid custodian for institutional digital asset investors created by the Japanese investment bank Nomura, digital asset manager CoinShares and digital asset security company Ledger.

The U.S. the U.S. Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 22 individuals and 104 entities operating in 20 countries for their role in facilitating Russian sanctions evasion, including John Desmond Hanafin, Founder of Dubai based Huriya Private, a fintech firm, who has an active Ethereum address included as an identifier on his SDN List entry.

Hanafin is the founder and CEO of Huriya Private FZE LLE, a Dubai-based financial services company also sanctioned today for its role in funneling Russian funds into the UAE. 

According to OFAC’s press release, Hanafin in his role at Huriya has been working since the outset of the Russia-Ukraine War to help Russian nationals protect their assets from sanctions. Much of this activity has involved helping Russian nationals move their money into UAE bank accounts and obtain fraudulent passports. 

As per Chainalysis blog, John Hanafin’s on-chain transactions may shed light on Huriya’s Russian sanctions evasion operations.

OFAC included a single Ethereum address as an identifier on Hanafin’s SDN list entry. That address is 0x38735f03b30FbC022DdD06ABED01F0Ca823C6a94. Since becoming active in January 2022, that address has received roughly $4.9 million worth of cryptocurrency, mostly in Tether (USDT).

According to Chainalysis article, across the 75 USDT transactions received by Hanafin, there were several in amounts with following ranges  $5,000 – $10,000, $15,000 – $25,0000, $100,000 – $150,000.

Chainalysis included some examples of transaction within those ranges on Chainalysis Reactor graph.

While Chainalysis states that they cannot be sure that any of the payments to Hanafin’s wallet reflect citizenship by investment purchasing, they do point out, “ it certainly appears possible given this is a service Huriya offers, and Hanafin’s work acquiring false passports for Russian nationals as described by OFAC.”

Chainalysis adds, “ As for the high-frequency payments to Hanafin’s wallet that came in smaller amounts, it’s possible that those were related to lower-cost services Huriya offers, such as establishment of UAE bank accounts or corporate structuring.”

Chainalysis explains that while crypto may still play a role in Russian sanctions evasion, the transparency of blockchain means that blockchain analysis combined with open source data can open up valuable avenues for investigation. 

Universal Digital AEDU and Canadian Aquanow have received MVP ( Minimum Viable Product) provisional license approvals for several virtual asset licenses from Dubai’s Virtual asset regulatory authority (VARA). Universal Digital (AEDU) has applied for advisory license, broker dealer services, virtual asset custodial license, crypto exchange license, crypto lending and borrowing license, as well as management and investment service license.

In addition Canadian headquartered, digital asset platform has also received MVP provisional approval for advisory license, broker dealer license, and management investment service license.

Aquanow is a privately funded, infrastructure and liquidity provider that enables institutional and enterprise use-cases for digital assets. The company currently has 200 institutional clients, serving customers in 30 plus countries with 70 asset pairings.

This is another representation of increased interest in the UAE as a center for virtual assets, blockchain and crypto.