Crypto Transfer & Settlement Services — Fast, Traceable, Compliant Money-in/Money-out
Launch and scale crypto transfers (Crypto↔Crypto / Crypto↔wallet / wallet↔wallet) with verified-instruction workflows, receipts, and Default Rules that withstand inspections.
Advising VASPs on cross-border permissions, Travel Rule alignment, receipts, error-resolution/refunds, and FMI-grade Default Rules.
WHAT THE VARA TSS LICENCE COVERS
“Crypto Transfer & Settlement Services” covers transmission or transfer of VAs from one Entity to another or to a VA wallet/address/location, and the settlement that completes it.
Note: The Transfer & Settlement Services Rulebook (TSSR) applies in addition to the four compulsory rulebooks (Company; Compliance & Risk; Technology & Information; Market Conduct).
Where your flow involves exchanges or conversions, you remain responsible for completion and must use a VARA-licensed Exchange VASP (or a VARA-approved non-Dubai entity).
SERVICES YOU CAN OFFER UNDER THIS LICENCE
VA transfer
VA transfers (on-/off-platform; domestic & cross-border) with verified client instructions, full audit trail, and receipts at instruction and at finalisation.
Conversion-assisted settlement
Conversion-assisted settlement (e.g., VA→fiat or VA→VA during the flow) using a licensed/approved counterparty; fee/flow disclosure; you stay directly responsible to the client for completion.
Stop/revoke & error
Stop/revoke & error-resolution procedures (where contractually allowed) and refund/restore within 24h if you detect wrongful/defective execution.
Default Rules
Default Rules for client non-performance (close-out, loss allocation, segregation/portability, solvency protection, contribution arrangements).
Global-standards alignment
Global-standards alignment for FMI-style practices (matching, deliveries/payments, settlement performance monitoring).
COMPLIANCE GUARDRAILS THAT KEEP YOU OUT OF TROUBLE
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CBUAE & cross-border legality |
Confirm end-to-end permissibility in all relevant jurisdictions and comply with applicable CBUAE rules for payments/remittances. |
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AML/CFT & Travel Rule |
Implement Travel Rule for transfers ≥ AED 3,500; counterparty VASP due diligence; records ≥ 8 years; risk-based monitoring. |
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Property interests / use of client VAs |
No sale/pledge/convert/encumber unless expressly consented by the client as part of TSS; obtain explicit instruction upfront. |
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Authorisation & liability |
Maintain instruction verification; if unauthorised/incorrect, refund/restore within 24h and trace outcomes; sender VASP remains liable unless it proves no fault. Keep instruction records for 8 years. |
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Client disclosures (before onboarding) |
Irreversibility risks; on-chain finality timing; technical outages; fee schedule; execution times; stop/revoke rights (if any); allocation of liability; error resolution; periodic statements & valuations; receipts; Retail notice/termination periods (60/30-day rules). |
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Public website disclosures |
Conflicts & how managed; privacy/whistleblowing/complaints; introducer/referral terms; identity of any third-party holder/custodian. |
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Technology & resilience |
Key/wallet controls (no single point of failure), DLT tracing for transactions, BCDR and 72-hour incident notification to VARA; CISO in post. |
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Market Conduct |
Written Client Agreements, investor classifications, public licence details & Responsible Individuals, risk statements; complaints handling SLAs. |
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Financial prudentials (Company Rulebook) |
Paid-up capital for TSS = higher of AED 500,000 or 25% of fixed annual overheads; Net Liquid Assets ≥ 1.2× monthly Opex; Reserve Assets = 100% of client liabilities (same-asset); mandatory insurances. |
What CRYPTOVERSE Legal delivers
Licensing strategy & submissions
activity mapping, governance, prudential overlays; cumulative-rulebook matrix.
Instruction & liability framework
Verified-instruction SOPs, callback/PKI/2FA controls, refund/restore workflows, root-cause & trace procedures, 8-year records.
Client documentation & disclosure
Client Agreement inserts (risks, fees, stop/revoke, liabilities), website disclosures (conflicts, third parties, introducers), receipts templates.
Travel Rule & AML
Counterparty-VASP DD, information payloads, sunrise approach, on-chain analytics and alerts.
Default Rules & FMI alignment
Legally enforceable default regime; close-out/portability; stress-event playbooks; annual testing.
Tech & resilience
Wallet/key ceremonies, segregation, DLT-tracing, BCDR, incident notification, CISO/DPO appointments, TLPT/vuln testing cadence.
OUR PROCESS
(FAST & REGULATOR-READY)
Scoping call
Flows (push/pull, internal ledger vs on-chain), conversion needs, jurisdictions.
Regulatory blueprint
Artefacts, prudentials (capital/NLA/Reserves), insurance, Board/roles.
Policy build-out
Instructions & refunds; disclosures & receipts; Travel Rule & AML; Default Rules
Tech & controls
Wallets/keys, DLT-tracing, BCDR, 72-h incident plan, TLPT/testing.
Regulator interactionS
Submissions, notifications, approvals.
Go-live support
Periodic reviews, annual rule testing, disclosure upkeep, complaint SLAs.
Why CRYPTOVERSE Legal
Narrow-cast L&B expertise
We translate the Rulebook into pragmatic, auditable controls.
Evidence-ready
Every control is rule-mapped and inspection-proof.
Speed with substance
Timelines compressed without cutting compliance corners.
Speak to a Crypto Lawyer
Book a Strategy CallFAQs
Yes—use a VARA-licensed Exchange VASP (or VARA-approved third party) and disclose roles/fees; you remain responsible for completion.
One at instruction (status, amounts, fees, routing, liability/refund statements) and one at finalisation (credit timestamp, amounts, full conversion details). Keep all receipts 8 years.
Permitted only if your Client Agreement/terms allow it and the flow supports it; disclose procedure in advance.
Refund/restore within 24 hours of awareness; investigate and notify the client of the outcome; your liability depends on fault proof.
Paid-up capital (≥ AED 500k or 25% Opex), NLA ≥ 1.2× monthly Opex, Reserves = 100% client liabilities; specific insurances required.