On February 24th 2023 FAFT released its latest grey and black list. For those who are on the grey list it means that these jurisdictions are under increased monitoring and are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing.

As per the recent announcement by FATF, “When the FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring. This list is often externally referred to as the “grey list”.”

Of the Arab countries on the grey list, was Jordan. It was on the list because of risks in virtual assets. As per FATF one of the reasons for it being on the list was because it needed to address strategic deficiencies including “completing and disseminating the money laundering and terrorist financing risk assessments of legal persons and virtual assets.”

It was interesting to see the term virtual assets in relation to Jordan because Jordan has not been on the list in terms of countries with high crypto ownership or transactions. Other countries such as Egypt, Morocco, and Lebanon are much more active in crypto. yet FATF chose to include the risks of virtual assets as one of the reasons it was one the grey list. 

According to Triple A crypto ownership report, the percentage of Jordanians who own crypto is just 1.5 percent equivalent to 170,000 people as of January 2023 an increase from 1.25 percent in 2022.

Concurrently, the IMF after its technical report on Jordan’s Central Bank feasibility for the launch of retail CBDC after a three month mission, recently released its report. IMF gave Jordan’s existing payment market a positive review calling it well integrated.

Nonetheless, The IMF stated that an rCBDC would enhance financial inclusion by providing services to residents without smartphones and could also improve the domestic payment system by making its infrastructure available to PSPs and lowering the cost of cross-border transfers.

The IMF however warned to avoid disintermediation in the Jordanian financial system, as it could contribute to instability in times of stress. The IMF found that an rCBDC could increase cybersecurity risks as an attractive target. “Sound legal underpinnings for an rCBDC should also be created,” the report said. 

In its report the IMF noted, “RCBDC may offer some benefits, but it does not necessarily address pain points. On the other hand, a cross-border rCBDC could add value, particularly if the authorities coordinate with other countries in the region.”

Jordan’s Central Bank had announced in February 2022 that it was researching a CBDC. Cointelegraph article noted that a central bank proposal to introduce crypto trading met with resistance in the parliament.

Whatever the case, Jordan being on FATF grey list because of virtual assets risks is another reminder of the need to regulate crypto assets.

The Oman Capital Market Authority has announced that it will  establish the Virtual Assets Regulatory Framework to regulate and develop the market in the Sultanate of Oman.

The Capital Market Authority (CMA), which regulates and develops the Sultanate’s financial markets for the capital market and insurance sectors, is planning to establish the new proposed regulatory framework for Virtual Assets (VA) and Virtual Asset Service Providers (VASP). 

As per the press release, this move highlights the Sultanate’s growing recognition and the CMA’s proactive approach to develop the digital assets and fintech industry in Oman.

This important initiative in Oman was announced during a public stakeholders engagement session held at the CMA recently and being led by the CMA. By regulating and developing the virtual assets industry, the CMA aims to provide an alternative financing and investment platform for issuers and investors, while mitigating the risks associated with this asset class.

The CMA is in the process of defining a comprehensive and facilitative regulatory framework, which will include a new regulation to cover all virtual assets activities, a licensing framework for all VASP categories and a supervisory framework to identify, assess, and mitigate ongoing risks. The aim of this new regulation is to establish a market regime for virtual assets that includes rules to prevent market abuse, including through surveillance and enforcement mechanisms.

The proposed new regulatory framework is envisaged to cover activities such as crypto assets, tokens, crypto exchanges, and initial coin offerings, among others. The regulation for virtual assets in Oman is important, as it will provide a clear and secure framework for the growth of the virtual assets industry. The move towards digitalization and the adoption of virtual assets aligns with the Sultanate’s Vision 2040 of a digitally transformed economy and financial sector, while attracting foreign investments into Oman.

The CMA has also appointed XReg Consulting Limited, an international policy and regulatory consultancy specializing in virtual assets, and Said Al-Shahry and Partners, Advocates & Legal Consultants (SASLO), an Omani law firm, to advise and assist the CMA. This collaboration brings together expertise in policy, law and technology to assist in the creation of a comprehensive regulatory framework for virtual assets in Oman.

Back in  June 2022 Oman Capital Market Authority  issued its new Securities Law (46/2022) which  stipulates that the authority can “Agree to application of technologies, virtual digital investments or any products or services in the areas related to the provisions of this law, as set out in the Regulation.”

Oman was only one of the first countries in the region to allow crypto mining , mining its first Bitcoin in December 2022.    While The Oman Water and Waste Water Services Company ( OWWSC), member of Nama Group, trialed a stablecoin linked to the Oman Riyal. The company signed an MOU with Oman based Digital Digits, the creators of Easy coins and Connected Chains to trial “ Hasalah” a stablecoin Wallet.   

The UAE Central Bank announced on Sunday 12th of February 2023 its nine initiatives for what it calls its financial infrastructure transformation program, the FIT program that will enable the Central Bank of the UAE to be among the top central Banks globally. One of the nine initiatives is the launch of a CBDC for internal and cross border payments, but where is the 10th, the one that will actually put the UAE on the map as the digital payment hub. Where is the UAE’s Central Bank digital asset payment and remittance regulation or rulebook?

So the UAE Central Bank has finally openly stated that it will be launching a CBDC ( Central Bank Digital Currency) for not only cross border payments but also UAE internal national payments. As per the release, the Central Bank Digital Currency (CBDC) would be utilized for cross-border payments and domestic usage in order to address the problems and inefficiency of cross-border payments and help drive innovation for domestic payments respectively.

Ofcourse the announcement that they will launch a CBDC is not surprising given the work the UAE has been doing in the realm of CBDCs over the years. 

In 2019, the Central Bank of the UAE (CBUAE) piloted a wholesale CBDC project with Saudi Central Bank named of “ABER.” A final report was published in 2020, which showed that “the distributed ledger technology would enable central banks to develop payments systems at both local and cross-border levels.”

More recently, the CBUAE, along with the BIS Innovation Hub Hong Kong Centre and the central banks of Hong Kong, Thailand and China,  implemented Project mBridge, a joint initiative experimenting with cross-border payments using a custom-built common platform based on distributed ledger technology (DLT) upon which multiple central banks can issue and exchange their respective central bank digital currencies.

In my previous blog article published on December 15th 2022, I alluded to the fact that the UAE Central Bank could be close to issuing its own CBDC.

At the end of January 2023, the UAE Central Bank and Central Bank of India signed an MOU to collaborate in the payments sector; fintech solutions and experimenting with a CBDC to facilitate cross border transactions.

The Central Bank of UAE as explained in the press release wants to become the financial and digital payment hub and a center of excellence for innovation and digital transformation.

H.E. Khaled Mohamed Balama, Governor of the CBUAE, said: “The FIT Program embodies the directions and aspirations of our wise leadership towards digitizing the economy and developing the financial sector. We are proud to be building an infrastructure that will support a thriving UAE financial ecosystem and its future growth. H.E added: “We will work with our partners to implement the Program, achieve its goals, accelerate the adoption of digital services in the financial sector and attract the best talent.”

The Program comprises implementation of nine key initiatives  mentioned below:

 

 

1.  Card Domestic Scheme: The UAE’s first unified, secured, and efficient card payment platform to facilitate the growth of e-commerce and digital transactions in the country.

2.  eKYC:  A  secure  and  user-friendly  platform  to  facilitate  non-face-to-face customer on-boarding and on-going customer due diligence.

3. Central Bank Digital Currency (CBDC): CBDC for both cross-border payments and domestic usage in order to address the problems and inefficiency of cross-border payments and help drive innovation for domestic payments respectively.

4.  Open Finance: Driving innovation and competitiveness as well as collaboration in the financial services sector through inter-connectivity and inter-operability among all players and institutions.

5. Supervisory Technology (SupTech): Advanced SupTech supporting the regulatory and supervisory processes.

6. Innovation Hub: A collaborative platform for engagement, research and development for Fintechs.

7.  Instant Payments Platform: A secure, efficient, and robust payment platform that will support financial inclusion and enable a cashless society through digital payments.

8.  Financial Cloud: A secure, resilient, scalable, and reliable sovereign financial infrastructure.

9. Excellence & Customer Experience: Supporting exceptional customer experiences and fostering a culture of excellence across the financial sector.

 

But where is the 10th most important initiative? Where is the initiative that actually will allow the UAE to be a digital payments hub? Where is the digital asset payment regulation guideline, the one that VARA in its recent announcement of regulations didn’t cover? Where is the digital asset payments initiative that the UAE Securities and Commodities Authority didn’t cover?

Who will regulate digital asset payments and remittance ecosystem if the Central Bank of UAE doesn’t? It would be hard to imagine the UAE as a hub for digital payments without digital asset payments as well. It will be hard to imagine UAE as a hub for crypto and blockchain companies if there is no regulation governing the crypto, virtual assets payment ecosystem.

Sources close to the matter told LaraontheBlock, ” The nine initiative announced today are only related to the financial infrastructure. There are other initiatives being worked on.” 

I wonder if it is prudent to announce nine initiatives and pass over the one most important initiative that everyone is waiting for. But it seems that the Central Bank are working on other initiatives and hopefully digital assets as a payment method are one of them.

During the UAE Digital Economy Council’s first meeting chaired by Omar bin Sultan Al Olama, Minister of State for Artificial Intelligence, Digital Economy, and Remote Work Applications, seven sub-committees were created including one for Blockchain, another for Fintech and one for investing in digital economy. 

The first meeting which discussed consolidating the UAE’s status as a global hub for the digital economy and a platform for digital innovation to boost the national economy, emphasized the importance of empowering national talents to excel technological areas and augmenting the digital economy’s contribution to non-oil GDP. 

During the meeting, the council approved the formation of seven sub-committees led by members of the council, to cover all goals of the UAE digital economy strategy in areas such as technological infrastructure and blockchain, e-commerce, financial technologies, investment in the digital economy sector, attracting skills and supporting start-ups.

Additionally, a committee was formed to specialize in digital economy statistics and prepare an annual report to measure the performance and indicators of the digital economy in the UAE and ensure sustainable progress in the digital economy.

The council also discussed strategic performance indicators for the digital economy and ways to enhance the UAE’s global position in developing the future digital economy model.

UAE Securities and Commodities Authority (SCA ) publishes the Cabinet Resolution No. (111)of 2022 regarding the regulation of virtual assets and their service providers and has noted which entities it will regulate and the penalties that can reach $2.7 million. 

As per the resolution, the regulation of virtual assets and their providers will be overseen in the UAE by the Securities and Commodities Authority, as well as the Central Bank of the UAE. It will also include local licensing authorities that include free zones, and financial free zones. 

As per the resolution virtual assets are defined as a digital representation of the value that can be traded or transferred digitally, can be used for investment purposes, and does not include digital representations of paper currencies, securities or other funds.

The activities that fall under virtual assets include the provision of virtual asset services in the UAE. 

As for virtual assets service providers , they are any legal person practicing one or more activities related to virtual assets or the related processes for the benefit or on behalf of a person, such as the operator of the virtual assets platform, the broker of virtual assets and the custodian of virtual assets, and any other activities in accordance with the provisions of this Resolution.

The resolution defined Virtual Assets Platform as a digital platform for listing, trading and transferring ownership of virtual assets, conducting related clearing and settlement processes, and storing and saving information and data through distributed ledger technology or any other similar technology.

According to the resolution it aims to develop the legislative system of the virtual assets sector in the State, its related activities and service providers in a way that defines and guarantees the rights and duties of all related parties. 

The resolution will also regulate the virtual assets sector in the State and its related activities and service providers and will be compliant with all all provisions of the Federal Decree-Law No. (20) of 2018 concerning Combating Money Laundering Crimes, Combating Financing of Terrorism and Financing of Illegal Organizations, as amended, and its executive regulations and applicable legislations related to the sector.

The resolution also seeks to protect investors in virtual assets from illegal practices.

The virtual asset regulation will cover all entities within the UAE including free zones, except for those within financial free zones such as ADGM and DIFC, which work with entities offering digital securities and digital commodity contracts. 

There is an exception for entities working in the virtual assets for payment purposes, and stored value facilities. They will fall under the jurisdiction of the Central Bank of UAE. However virtual asset platforms are not included under Central Bank jurisdiction.

As per the decision no one can engage in virtual asset activities unless they are licensed. The UAE Securities and Commodities Authority will offer licenses for the following activities:

a. provision of Virtual Asset Platform operation and management services;

b. provision of exchange services between one or more forms of virtual assets;

c. provision of Virtual Asset transfer services;

d. provision of brokerage services in trading operations in Virtual Assets;

e. provision of Virtual Asset custody, management, and control services; and

f. provision of financial services related to offering and/or selling by the issuer to the Virtual assets, or participating in providing those services.

Licensed entities must meet minimum requirements such as not being a sanctioned or on terrorism lists especially those concerned with combating money laundering and combating the financing of terrorism and illegal organizations, and not be subject to any criminal investigations within or outside the State during the submission or study of the application for registration, and that no final judicial judgment has been rendered against him in the crime of money laundering, financing terrorism, or financing illegal organizations;

In addition the entities seeking license need to implement technical systems that are able to protect investor data in accordance with international best practices, current technology and/or cybersecurity standards. 

These entities also need to meet the capital requirements and conditions, credit guarantees, insurances, compliance management systems and other rules in accordance with the executive resolutions issued by the Authority.

Finally the UAE SCA has the authority to suspend listing or trading virtual assets, or the technologies used by these services providers, or the operation of virtual asset platforms. 

The authority can impose financial fines not exceeding AED (10,000,000) ten million AED equivalent to $2.7 million.

This is the first time that the UAE has endorsed its onshore virtual asset regulations, it will now be time to see who can meet these regulations and who will not. 

The Saudi Central Bank (SAMA) released a press release where it confirmed that the Central Bank is continuing to experiment on Central Bank Digital Currencies (CBDC).  SAMA is currently working on a project that focuses on domestic or national wholesale CBDC use case in collaboration with local banks and FinTech’s.

Experts explained to LaraontheBlock that this is a CBDC for local wholesale bank settlements. 

This project is part of SAMA’s ongoing research and experimentation on CBDC. SAMA is seeking to research and explore the economic impact, market readiness, and  potential robust and fast applications of a CBDC based payment solution. 

As per the news, SAMA seeks to review policy, legal and regulatory considerations before moving to the next phases of the CBDC journey to contribute to achieving the objectives of Saudi Vision 2030.

H.E. Fahad Almubarak, Governor of SAMA stated “Local banks and payment companies will always be a cornerstone of this project and its implementation, we have engaged both local banks and FinTech’s, as well as other market players and third party consulting and technology providers, to gain a better understanding of CBDC’s functionality and to test various design options.” 

Noted as well, is that SAMA will continue to experiment on CBDC solution as an infrastructure enabler of innovation in financial services that has the potential to contribute to a more resilient payment ecosystem and accelerate digital transformation in the local financial sector.

SAMA stresses that although no decision has been made regarding the introduction of CBDC in the Kingdom, it continues to focus on exploring the benefits and potential risks of implementing CBDC. This will contribute to informed decision-making within SAMA and to CBDC explorations within the central banking community.

Prior to this announcement, SAMA had hired Mohsen Al Zahrani as Head of Virtual assets and CBDC program. This seems to be the first fruit of efforts made. 

In 2020  SAMA successfully conducted CBDC experiment “Project Aber” in 2019, an initiative in collaboration with the Central Bank of the UAE to examine whether distributed ledger technology could contribute to seamless cross-border payments.

During the 2023 World Economic Forum’s session on Financial Institutions innovating under pressure, the Saudi Arabian Minister of Finance Mohammed Al Jadaan states that while CBDCs have privacy issues they are fantastic tool in developing countries.

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, Crypto.com, 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.”

The UAE Cabinet recently updated some of its legislation which  included those pertaining to virtual businesses and virtual assets. The UAE is considering the provision of services and the conduct of business and activities related to virtual assets and virtual businesses based on its new commercial law.  As such businesses dealing either virtually or with virtual assets are considered commercial businesses within the UAE as on shore businesses. This comes after the UAE Cabinet of Ministers issued its decision on virtual assets regulation in December 2022 and which will come into effect in January.

As per UAE’s Undersecretary of the Ministry of Economy, Abdullah Al Saleh, developing the business sector is a strategic goal for the state, and providing a legislative environment that stimulates its growth is a top priority.

His comments were made during a media briefing, organized by the Ministry of Economy, to introduce Federal Decree Law No. 50 of 2022 regarding commercial transactions in the country, with the participation of Ibrahim Al Zaabi, Assistant Governor of the Central Bank for Monetary Policy and Financial Stability, and Dr. Maryam Al Suwaidi, CEO of the Securities and Commodities Authority.

As such the UAE Ministry of Economy has issued a new commercial transactions where the most prominent features include reduction of the age of legal capacity to practice business to 18 years, establishment of a legal  reference for commercial transactions for banking institutions to stimulate investment,  support to Islamic banking, amends the provisions related to establishment, regulation of financial markets, and finally support to businesses in tech sector especially digital field.

Al Saleh stated, “ The new law aims to support the commercial interests of the state and comply more with international trade,  strengthen the position of the UAE on the global trade map, keep abreast of international best practices in commercial transactions, and ensure the principles of transparency and clarity in them, as well as raise the country’s classification on relevant economic competitiveness indicators, including the Global Competitiveness Report, and the Ease of Doing Business Report. In addition the new law aims at accelerating the transformation of digital applications further in the business sector in the country, and strengthening the position of the UAE as a center for business activities in the areas of technology, innovation and sectors of the new economy, and reviewed the most prominent provisions and outputs of the new law, which confirms State’s proactive approach.”

The UAE will be creating a virtual business system, the commercial store and commercial transactions, through the means of modern technology, and those that take place in virtual environments, in addition to those provided in realistic standard ways, as well as considering the provision of services and the conduct of business and activities related to virtual assets as virtual businesses in accordance to UAE’s Council of Ministers Legislation regulating virtual assets and their service providers.

This includes

• Giving authenticity to the virtual business so that the same provisions applied to it with respect to similar ones presented realistically.

• Giving legitimacy and authenticity to real and virtual commercial books.

• Selling by public auction of movables instead of used movables and making bids available through a licensed electronic platform or hall or through various modern technology means.

 Dr. Mariam Al-Suwaidi, CEO of the Securities and Commodities Authority, added, “The most noteworthy provisions presented by the new law deal with the securities sector in addition to the fact that the Authority is to consider the business of virtual assets as a commercial business, and this provision gives a privilege to the virtual assets sector. With the issuance of the new law it has been confirmed that businesses related to virtual assets are considered commercial businesses. Therefore, the provisions of this law and other related laws will apply to those who will deal in the activities of this sector, and benefit from the privileges included in the new law, such as the provisions regulating the trader and allowing new age groups to practice business, noting that the Cabinet of Ministers already issued its regulating decision last December for virtual assets, and will enter into force mid-January.” ( Note no public information is available on the Cabinet of Ministers decision for virtual assets.)

The announcement comes in parallel with the recent announcement by the Abu Dhabi based crypto and Blockchain associate to set up a Regulators Committee to help drive change and learn lessons in the wake of last year’s FTX exchange collapse. Jehanzeb Awan of the Middle East, Africa and Asia CBA (MEAACBA) states, “It is pivotal for the industry to help the investing public understand the opportunity and corresponding risks that come with investing in cryptocurrencies. The importance of holistic regulation to minimize regulatory arbitrage is key to reducing the impact of the recent events as well as bringing confidence back to the industry.”

The MEAACBS said its board is setting up a Regulators Committee which aims to bring together the key regulators in the regions covered by the association, to work together in building regulatory regimes that allow for effective oversight of the crypto industry.

On the LinkedIn page of Henson Orser, it states that he is the CEO (Chief executive Officer) of Dubai’s virtual asset regulatory authority better known as VARA as of January 2023. This comes as VARA reveals its final crypto framework in the next few weeks.  Previously Orser had held the position of President and Acting CEO of Komainu and was the Co Head of Global markets for Japanese digital bank Nomura.

As most know, VARA was created in March 2022 to regulate the virtual assets ecosystem and grant blockchain and crypto licenses in Dubai. A graduate of Princeton University, Orser is VARA’s first CEO.  Orser is well versed on digital assets, and custody solutions given his former role at Komainu. It is noteworthy that Komainu is one of the few Blockchain enabled DeFi custodians with a presence in Dubai that has been granted an MVP (Minimum Viable Product) license. The only other one is HEX Trust.

While VARA’s website has yet to note the new appointment, in an interview with the Block crypto, Orser stated, “VARA is the first purely virtual asset regulatory authority that is gold standard, tier one and even passportable to other jurisdictions.” He also notes it is compliant with the crypto regulation published by the Financial Action Task Force.

VARA is currently preparing for its MVP phase to allow for approved licensees to fulfill the pre-conditions required to operate. This means that MVP licensees are not allowed to provide any regulated services until VARA’s operationalization of the MVP Phase.

Orser clarified to LaraontheBlock, ” The provisional license during the MVP phase allows for firms to get office space and apply for VISAs etc. They won’t be able to commence operations until final rules and licensing.” 

Orser told The Block crypto that finalized rulebooks for crypto firms will be published on VARA’s website “within weeks.”

In December 2022, Laraontheblock wrote about an article on Pinsentmasons legal firm website which discussed Dubai VARA’s Full market product regulatory regime for virtual assets upcoming rollout. The legal expert Tom Bicknell stated in the piece 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 would 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

VARA had granted Binance, and FTX MVP licenses, however FTX’s license was later suspended and revoked after its downfall.

Dubai’s Virtual Assets Regulatory Authority (VARA) was also the first regulator to enter the Metaverse with the establishment of its Metaverse HQ in  ‘The Sandbox’.

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.”