VARA has identiﬁed seven distinct Virtual Asset (VA) activities that span the current spectrum of available VA services. The list of activities is designed to be ﬂexible and evolutionary as the global sector grows and develops in tandem. The industry is encouraged to view this list of activities as a solid foundation that oﬀers room for innovation, rather than a ﬁnite register.
VASPs seeking to oﬀer the below services must apply for and receive a licence from VARA before undertaking VA activities in Dubai.
A VASP can apply to be licensed for multiple activities and aggregate them under a single overarching licence. Save for Custody Services there is no specific need to segregate an activity and/or demonstrate independence of governance or arms-length association from another.
In the current list of seven activities, Virtual Asset Custody Services is the only activity that is required to be segregated from other Virtual Asset Financial Services licence categories. In this instance, a VA Custodian must be set up as a distinct legal entity with a standalone licence.
Licensed VASPs are prohibited from proprietary trading or trading their Group’s portfolio of assets.
VASPs that are licensed to undertake multiple activities must meet the requirements for each activity in full, and maintain due conformity at all given times.
Any VASP or traditional economy entity seeking to offer the below VA services must apply for and receive a licence from VARA before it can begin VA activities in or from the emirate of Dubai, whether offered to customers that are residents of the emirate, or to global customers where the activity is permissible.