In a recent article on Pinsentmasons legal firm website, the article discusses Dubai VARA’s Full market product regulatory regime for virtual assets and its upcoming rollout.

The legal expert Tom Bicknell states, that after VARA’s roll out of its minimum viable product license regime which allowed participants to undertake their activities within an agreed limited scope and specifically to their authorized market segment, VARA will soon be launching its FMP framework which will seek to monitor global trends of the virtual industry and where appropriate issue further rules and guidance

Tom Bicknell of Pinsent Masons states, “Encompassing the learning’s from its MVP licensing stage and widespread industry engagement, VARA’s introduction of the FMP ( Full Market Product) license will serve as a firm footing for the next stage of growth for the UAE’s leading virtual asset industry.”

Once the rollout begins, MVP license holders and other VASPs will have to apply for an FMP license to undertake their activities in the market. The FMP regime is structured around ensuring that anti-money laundering and combating the financing of terrorism (AML/CFT) compliance standards are met in accordance with the Financial Action Taskforce’s recommendations for VASPs. VARA said the FMP regime will also apply ongoing internal controls, corporate governance and conduct of business rules appropriate to the risk profile of the applicant.

Bicknell adds, “VARA is undertaking engagement and consultation with market participants as part of its development of the FMP framework with a version of the framework expected to be released shortly. It is worth noting that VARA has made clear that, notwithstanding the release of the FMP framework, the regulator will seek to monitor global trends of the virtual industry and where appropriate issue further rules and guidance.”

On October 27th 2022, Q9 Capital published a press release where they unilaterally announced that they had received a provisional virtual asset approval from Dubai’s Virtual Asset Regulatory Authority (VARA). LaraontheBlock since then has continuously been checking VARA’s website and no Q9 to be seen anywhere. Q9 is a crypto investment management platform offering capabilities to crypto and TradFi firms. So it should be on VARA’s website under TradFi, DeFi Asset Managers section, but it isn’t.

VARA lists all the entities which have applied for a license and have provisional approval. So for example on VARA’s website under Native Crypto Exchanges, users can see Binance [Issued MVP Licence], BitOasis, Bybit, CoinMENA, Crypto.com, FTX Exchange FZE [Suspended MVP License], GCEX, Huobi, MidChains and OKX.

Then under TradFi DeFi Custodians, you have the recently approved Hex Trust [Issued MVP Licence], Komainu [Issued MVP Licence] and then you have those who applied and have a provisionary license but not a full MVP one that include Monstera and Zamp.

In TradFi | DeFi Asset Managers there is Brevan Howard, Fintonia Group, NineBlocks and NOIA Capital. While under TradFi | DeFi Financial Services you have Amber Group, Equiti, Scallop, and TPS Capital

With Native Crypto-Content | DLT Platforms listed are Calvin Cheng Web3.0 Holdings and Woonkly Labs while in TradEcon | DeFi Services there is BRE Holdings, Eros Investments, Hike, and Prypto

Two weeks since the announcement and no Q9. This is despite the fact that VARA is quick to update its website when it has approved or provided preliminary approvals or MVP licenses. In addition in many cases it also publishes a press release.

Q9 had stated that this approval came as it expanded into the UAE and applied for a full operating license in accordance with VARA requirements.  As per the release, Q9 products and strategies can be created and executed on Q9’s platform, such as systematic investment portfolios and white-labeled offerings, within VARA’s framework and distributed globally in an automated, transparent, regulated and compliant manner.

The release added, the full operating license, once received, will allow Q9 to extend products and services to qualified investors and financial service providers. Q9 will also establish a regional hub in Dubai to contribute to developing the ever-expanding virtual asset ecosystem both in Dubai and globally.

The press release even goes on to say that the provisional approval is a major milestone that follows a number of registrations for Q9’s local entities in Hong Kong and Dubai. As a regulation-led platform with robust compliance and security controls that have consumer protection and market integrity at its core, the registration further strengthens Q9’s position.

James Quinn, Managing Partner of Q9, noted “Dubai’s Virtual Assets Regulatory Authority is a testament to the country’s forward-looking stance on digital assets and its willingness to support the industry through collaboration. We look forward to participating in the authority’s robust compliance framework and continue building partnerships as we expand our presence in Dubai to roll out additional services and enhanced products for the region.”

But until LaraontheBlock, sees the Q9 name on VARA’s website, Q9 ‘s provisional preliminary approval is still hanging in the wind!

Dubai’s regulator is currently pushing forth its crypto custodial licenses. Last week VARA ( Dubai Virtual Asset Regulatory Authority) provided Komainu DeFi, digital asset custodian with a provisionary license and today it has provided Hex Trust, fully licensed and insured provider of bank-grade custody and associated services for digital assets a Minimum Viable Product (MVP) license. 

The MVP license will allow Hex Trust to provide a wide range of virtual asset services to institutional clients and sophisticated investors] in Dubai within its framework for virtual asset service providers (VASPs). The range of services Hex Trust can now provide includes Virtual Assets custodial services, Broker-Dealer Services and Staking Services. 

 Hex Trust opened its Dubai office in June 2022, which is run by Filippo Buzzi, and serves as its headquarters for the MENA region.

Filippo Buzzi, Regional Director MENA of Hex Trust, commented, “Becoming one of the first virtual asset companies and custodian to receive the license is a big step for Hex Trust as we establish ourselves in the MENA region. We recognize the enormous potential this region has to build one of the leading virtual asset hubs in the world. Hex Trust looks forward to expanding our client base in Dubai following the license approval and making a positive contribution to the VA ecosystem in the region. 

Alessio Quaglini, cofounder and CEO of Hex Trust, commented, “From day one, Hex Trust was built to follow the strictest compliance policies and adhere to regulatory standards across the main jurisdictions. Being amongst the first companies to be granted the MVP is exciting, given the enormous potential of the sector in Dubai.”

Komainu, listed on VARA website as a DeFi (Decentralized Finance) digital asset custodian has received its minimum viable product license from Dubai’s Virtual Assets Regulatory Authority (VARA). This is following the issuance of its provisional approval in July 2022. This is a interesting development given the recent FTX scandal and the migration of crypto wallets from centralized exchanges to self custody.

Komainu can now offer an approved range of virtual asset related services to institutional investors in Dubai within an internationally benchmarked legislative framework for virtual asset service providers (VASPs) following completion of its readiness requirements.

The transition to an MVP license, from a provisional approval received earlier this year, means the firm can provide institutional clients in the UAE with Virtual Assets Custodial Services and Virtual Assets Management Services.

Komainu MEA is the first ‘dedicated’ institutional digital asset custodian to receive its MVP license approval from VARA.

Helal Saeed Al-Marri, chairman of VARA stated, “In this current phase of heightened global appreciation for responsible virtual asset participant, VARA is pleased to on board our first tradFi VASP Komainu to join the MVP phase of the regulatory regime. Participation from the VA specialist ventures of deeply respected global financial institutions, allows VARA the opportunity to structure interoperable guidelines and risk mitigation levers for secure market operations.”

Nicolas Bertrand, CEO of Komainu, commented: “Komainu actively works with regulators, partners, and our clients to make sure that our platform and the overall industry is held to the highest of standards to facilitate the wide adoption of virtual assets by institutions. With the full MVP license now granted by VARA, we look forward to launching our services in the MEA region and assist institutions gain exposure to virtual assets, whilst relying to secure and regulated virtual asset custody services.”

Komainu’s CEO is currently attending the AIM Investment Summit in Dubai UAE.

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. 

As the FTX debacle unfolds and FTX files for bankruptcy, CEO steps down, UAE VARA ( Virtual Asset Regulatory Authority) in Dubai has suspended FTX’s license. FTX MENA users brought in high revenues for FTX as it was considered as the third biggest revenue region for FTX. 

While the crypto markets are in turmoil across the globe, it will also have an effect on the MENA region. FTX MENA CEO Balsam Danhach told Reuters in a previous interview,  “Our license expands to retail customers as well, however, it will be a gradual scale up to ensure that we approach the retail market within the guidelines set by the Virtual Assets Regulatory Authority.”

Danhach also told zawya in a recent interview that their operation in MENA region is the second to third region in terms of global revenue performance. At the time FTX had 6 million users with a trading volume of $12 billion per day.

He stated in his interview with Zawya, talking about MENA and the importance of their license in UAE, “We are not talking about a region contributing a small percentage to our revenues but a region which is among our top three in terms of revenues. Here there are higher volumes per user.”

While FTX officially launched in UAE on October 31st 2022, its CEO had commented that from July 2022 until October FTX was testing backend migration of their existing user base from MENA onto their FTX MENA platform. FTX was offering the same access to all the services offered globally through the local FTX page. He stated at the time, “We are working on trading in UAE dirhams and accessing local banks.”

FTX MENA replying to a post on LinkedIn stated that they had not actually commenced operations locally. ” FTX MENA would like to clarify that the announcement of receiving its MVP License indicates that we are only able to commence readiness measures. Rigorous pre-conditions set by VARA have to be met by FTX MENA before undertaking any active market operations in the UAE. FTX MENA confirms that we are still in the readiness preparation phase and have hence not onboarded any clients nor engaged in any active operations locally as we have not received VARA approval to do so.” 

FTX Exchange, was the first Virtual Asset Service Provider (#VASP) to receive the MVP license to operate its virtual asset (VA) exchange and clearing house services from Dubai’s Virtual Assets Regulatory Authority (VARA).

Given the comments made by FTX MENA CEO,  it seems that there will be an effect on a number of crypto traders in the region. What could be worrisome is how will this play into the crypto growth in the region, and UAE’s stance on crypto and crypto regulation.

Crypto mining is an integral part of the development of crypto economies. As the MENA region opens up its economy to digitization and crypto-related activities and as the world is challenged by an ongoing energy crisis, MENA is probing to become an attractive destination for crypto mining.

While the biggest crypto mining markets are currently in the USA, China, Kazakhstan and Canada, the energy crisis and the crypto bear market could help the GCC become a leading crypto mining hub.

Mohamed El Masri, founder and CEO of Permianchain, which operates Bitcoin mining data centers in Canada using wasted energy, states, “The adoption and implementation of blockchain data center infrastructure can support the digital stability and financial security of the GCC region. Hypothetically, the GCC has the opportunity to attract close to $1.0 trillion in economic growth by laying the groundwork for powering the digital economy.”

El Masri confirms the main challenge is calling out the financial regulators, mainly in the financial free zones, to stop taking the “enforceability approach” and take a “regulate-first approach.”

Nonrenewable resources to boost mining 

El Masri also mentions that given that the GCC is an oil and gas-rich region, there is an abundance of natural gas energy being wasted each day. Notably, such gas energy supports the implementation and commissioning of low-cost power plants to attract bitcoin mining companies from all over the world to set up in the region.

According to him, this will allow the region to become a leader in providing field-generated electricity “to power the future digital economy all while reducing emissions and decarbonizing the GCC’s oil and gas sector.”

The World Bank has reported that the MENA region accounted for 40% of the world’s flaring, with Iran, Iraq and Algeria generating 75% of MENA’s flaring. Meanwhile, Saudi Arabia, Kuwait, UAE and Qatar have low flaring intensity.

Adopting new technologies

Munaf Ali, founder and CEO of UAE-based Phoenix Group, involved in crypto mining equipment sales and projects, believes MENA is fast moving toward crypto and blockchain adoption.

“The Middle East is fast helping the global diversification of jurisdictions which are friendly to operate in,” Ali states. “This goes for countries where crypto firms can set up, whether they are crypto exchanges or mining operations.”

Ali confirms that GCC governments have started to address this by recognizing these new business activities and are issuing licenses to crypto market participants.

The Phoenix CEO espoused other benefits, including job creation, the development of a green renewable energy industry, and the generation of crypto/USD for circulation inside the local economy which in turn boosts economic activity.

Growing interest in mining

UAE investment firms have also shown interest in crypto mining investments. Nabyl Al Maskari, executive chairman of Al Maskari Holding, in a panel discussion during the Security Token Summit in June 2022, noted that there will be significant crypto mining investments happening in the UAE.

“We will have significant crypto-mining investments because the UAE is a low-cost energy producer,” Al Maskari certifies. “We are in the solar belt and have nuclear power with two reactors online. We can as such mine green Bitcoin or other tokens that come out.”

During Binance Week 2022, Khalifa AlJaziri, AlShehhi, Commercial Affairs Regulatory Sector Projects advisor at the Ministry of Economy in UAE, claimed that the Dubai World Trade Center Authority (DWTCA) would be legislating the crypto mining sector. He stated, “We are setting the guidelines and rules needed to regulate crypto mining within this crypto framework.

The UAE is not the only country that has shown interest in crypto mining. Oman Investment Authority (OIA) took part in a $350mn equity round in Crusoe Energy Systems. The US firm helps oil and gas producers cut flaring by using stranded natural gas to power cryptocurrency mining. Crusoe systems set up operations in Oman as well. 

Pierre Samaties, global head of Crypto Economy and Energy, reaffirmed that Bitcoin mining in the region is growing.

“Given we have a huge difference between the summer load curve and the winter load curve, Bitcoin mining helps to support renewable energy investments to increase utilization of the asset by using it during downtimes for Bitcoin mining,” Samaties says. The executive says this helps to balance the energy system.

Samaties also affirms that Bitcoin mining is seen as a strategic asset, a cornerstone for building a crypto economy in the region.

For those who would like to read or share this article in arabic it is also on Cointelegraph MENA 

UAE Crypto Oasis ecosystem published its first annual report entitled the “Crypto Ecosystem in the UAE” with the collaboration of Roland Berger. The report highlighted the growth that the UAE has witnessed in its blockchain crypto ecosystem which has resulted in the employment of 7000 people across 1400 blockchain crypto entities currently operating in the country.

As per the report the number of blockchain crypto organizations is more than 1400 in total where 66 percent are native organizations and 34 percent are non-native. Saqr Ereiqat, Co-Founder and Managing Partner of Crypto Oasis Sentio, the investment arm of Crypto Oasis, told LaraontheBlock, “Based on the information we have the blockchain crypto ecosystem in UAE has employed approximately 7000 people.”

These 1,400 plus ventures are leveraging distributed ledger technologies and related technologies to build and provide new value propositions with Blockchain innovation. Interestingly the report confirms that the UAE is now home to 21 crypto exchanges including big names such as Binance and FTX who are now fully regulated under VARA (Dubai’s Virtual asset Regulatory Authority).

Another interesting finding in the report is the registered location of these blockchain and crypto entities. The majority 489 are based out of DMCC (Dubai Multi Commodities Centre) which was one of the first free zones to develop a crypto center. Interestingly IFZA (International Free zone Authority) houses 150 crypto and blockchain entities, while the Dubai World trade Centre, the home of VARA houses 48.

DeFi one of the biggest sectors in the blockchain crypto space is also mentioned in the report. As per the report DMCC has noted that the total value locked into DeFi protocols was $20 billion at the start of 2021 and increased exponentially to $260 billion by the end of the year.

It is also expected that the global DeFi market will hit $507.92 billion by 2028. The report notes that DeFi projects in the UAE include decentralized platforms that allow you to store, exchange or use assets. While the report mentions news where some platforms will allow POS terminals that will allows DeFi to reach the masses in the UAE.

The ADGM (Abu Dhabi Global Market) recently opened its fifth regulatory laboratory sandbox program inviting fintech organization to pitch their ideas on decentralized applications. This is further stance than DFSA; the regulatory arm of DIFC has taken. DFSA recently came out with its crypto feedback statement where it notes that it will not be undertaking anything in DeFi so far.

Finally according to Roland Berger global survey it found that creating a crypto economy strategy is of high priority for 60 percent of executives. While the top three leading sectors in crypto are telco and tech, automotive, transport and logistics, and Construction & Real Estate.

The chairman of Belobaba, a crypto native hedge fund with a regulated security token, believes that Banks will become Dapps, and that this was the year of building crypto not a bearish year.

Five year old, Belobaba utilizes big data and AI in its investment decisions… The company is currently setting up its headquarters in the UAE as it seeks to get regulated in GCC region. The hedge fund is already regulated by the Gibraltar Financial services commission and operating legally in the USA, as well as in Spain and Estonia.

Lluís Mas, chairman at BELOBABA spoke to LaraontheBlock expressing his views on the crypto market,the banking sector and why they are setting up their headquarters in UAE.

The hedge fund which currently has just $5 million under management is seeking to grow and expand. According to Mas, “I don’t consider it a bad year for crypto and I wouldn’t call it a bullish or bearish market, because just remember in the bearish markets of 2017-2019 Uniswap was created as were NFTs. For me this year is a building year as we see Ethereum merge and global regulations pick up.  Companies like Black Rock are entering the crypto space and financial actors such as Coinbase are offering crypto products to institutional investors. So for me it is definitely a building year.”

He also states that it is absolutely unfair to talk about a crash of Bitcoin. He says, “Bitcoin is at $20,000 today, it is a far cry from where it started out. We also see billions of dollars being invested in esports, DeFi and blockchain with many projects performing well.”

While he doesn’t foresee any significant changes in the crypto market in the next few months, he does see a pick-up in the middle of 2023.  Mas states, “While I don’t see much change in the crypto scene today, what I do know is that Ethereum is super cheap, and things should start to pick up in mid-2023.”

When touching on the topic of banking and its evolution, Mas mentions a well-known phrase in the crypto community, “ Banks are necessary but bankers not” As he explains, for some time bankers have not been taking care of their customers, which has led to the rise of neo banks. For him the future of banks is Dapps. He explains, “ Banks will slowly become dapps first they have the money and collateral, secondly they are working hand in hand with regulators, so in the next few years they will move to decentralized applications. Bitcoin is not here to destroy, but to make things more efficient and more user friendly. This is unstoppable and our role is to educate as many people as possible.” 

According to Belobaba chairman Dapps stand as the new paradigm and DeFi represents a change in the business model of traditional banking giving the opportunity to put the user at the centre of the value model. 

He notes that the banks of the future will not be huge with 1000 employees, but might be as small and nimble as entities such as Uniswap which has just a dozen or so employees. 

While Belobaba seeks to build one day a crypto bank, the company is also bullish on NFT gaming industry which will reach $800 billion by 2024. Belobaba also sees Security token offerings as a huge opportunity given it has grown by 84 percent. As for crypto, it is expected to become a $24 trillion market by 2030.

In terms of expansion, Belobaba is moving its headquarters to Dubai UAE, and are in the process of seeking a license. Mas says, “We are working with local partners to move our headquarters here. There are two reasons for our move; first given we are originally from Spain, the GCC as a geographic region is a comfort zone. In Gibraltar we are accustomed to the Commonwealth laws, as is the situation in UAE.”

He adds that the region is connected to Asia and other continents, and most in the region are open to investing.

While it might not be easy to get a license says Mas, he is confident that given their track record and strong partnerships such as that with RSM their efforts will be fruitful. He explains, “We are actively looking into Abu Dhabi regulatory ADGM, VARA in Dubai and Bahrain.  RSM is a global network of audit, tax and consulting experts that help us ensure our investors are protected.”

Recently Belobaba invested 1 million Euros in Team Queso, a leading esports club in mobile gaming.

Binance, crypto exchange has received its Minimal Viable Product (MVP) license from Dubai’s Virtual Asset Regulatory Authority (VARA). Local bank clients approved by VARA will be able to utilize the Binance platform. Users will benefit from higher consumer protection levels because Binance is now a fully regulated platform in Dubai.

Binance is now able to open a client money account with a UAE local bank and provide services to qualified customers. Services include, virtual asset exchange services, conversion between virtual assets and fiat currencies, transfer of virtual assets, custody and management of virtual assets, virtual token offering and trading services and virtual assets payments and remittance services

His Excellency Helal Saeed Almarri, Chairman of VARA said, “We are pleased to have Binance licensed to operate within the VARA MVP Programme. The VARA regime aims to strike an effective balance between value creation and risk mitigation, enabling open market innovation while assuring protection for the economically vulnerable. The MVP Phase, is designed for select global players across the value chain, that are committed to responsible industry participation and VARA looks forward to Binance being an active contributor, reinforcing Dubai’s commitment towards creating a next-gen secure ecosystem for this future economy.”

Changpeng Zhao (CZ), founder and CEO of Binance, commented: “At Binance we welcome regulations that are globally consistent, enable responsible innovation, protect users, and give them choice. VARA’s unique operating model is setting a benchmark for the global industry, and this most recent registration is an acknowledgement of our compliance and safety processes in the new regulatory framework.  We strongly believe there is a significant opportunity to work with our industry peers to develop consistent implementation standards around the world as we have been doing in Dubai.”

Alexander Chehade, Binance Dubai General Manager, noted: “Our registration in Dubai is a reflection of the country’s progressive stance on blockchain technology and its willingness to embrace this sector through collaboration. We look forward to continued partnership as we build upon our team and operations in Dubai to roll out additional services including local banking capabilities and enhanced products.”