PROPRIETARY PROPRIETARY TRADING OF CRYPTOCURRENCIES

Trade your own book in Dubai—clearly ring-fenced from client services, with the right notifications and guardrails.

We advise ARVA issuers end-to-end: licence, Reference-Asset mapping, reserve/custody set-up, legal opinions, audits, and marketing compliance.

WHAT “PROPRIETARY TRADING” MEANS HERE

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Under VARA, proprietary trading of cryptocurrencies is an entity investing its own portfolio of Virtual Assets (no client assets, no client service). It is not a licensable VA Activity in itself, but large traders must register with VARA and no one may hold out as a Licensed VASP unless actually Licensed for a VA Activity.

  • General prohibition (holding out). Only Licensed VASPs may carry out VA Activities “by way of business.” Do not describe yourself as a VASP unless Licensed by VARA.
  • Mandatory registration for large prop traders. If you invest ≥ USD 250,000,000 (equivalent) in VAs during any rolling 30 days, you must register with VARA. Registration does not authorise any VA Activity, and you may not accept or trade third-party assets.
  • Voluntary registration is available for entities seeking a commercial/free-zone licence and actively investing their own portfolio; it does not authorise VA Activities.

NOC pathway (operational). VARA indicates that Proprietary Trading may proceed under a VARA “No-Objection Certificate” (NOC) with regulatory oversight without a VA Licence; above USD 250m volume per month, registration applies. The NOC request is typically routed via your commercial licensor (e.g., Free Zone/DET) and accompanied by the Initial Disclosure Questionnaire (IDQ).

SERVICES YOU CAN OFFER UNDER THIS LICENCE

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Trade your treasury/house book

Trade your treasury/house book across approved venues or OTC on your own account only.

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Deploy liquidity

Deploy liquidity to strategies consistent with your board-approved policy (spot, basis, hedges).

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Operate wallets & controls

Operate wallets & controls for firm assets (no client commingling).

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Outsource execution/prime

Outsource execution/prime on arm’s-length terms (with diligence and audit rights).

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No client services

No client services (no brokerage, exchange operation, custody, lending/borrowing, management/advice).

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No holding out

No holding out as a VASP; no third-party assets under Reg. IV.A.7(c).

COMPLIANCE GUARDRAILS THAT KEEP YOU OUT OF TROUBLE

Policies

Treasury risk limits, market/credit/liquidity metrics, venue onboarding, sanctions/AML controls (Federal AML/CFT alignment).

Technology & security

Follow VARA Tech & Information Rulebook standards for access control, change/incident, and BCP/DR (applied as best practice even if not a VASP).

Market conduct

Insider dealing / market manipulation prohibitions apply in Dubai markets. (Reg. VIII).

Marketing

If you ever market anything in Dubai, you must comply with VARA Marketing Regulations.

What CRYPTOVERSE Legal delivers

NOC/Registration file

NOC/Registration file — IDQ prep, licensor coordination, VARA engagement, corporate object alignment.

Treasury & trading policy suite

Treasury & trading policy suite — limits, venues, counterparties, approvals, conflicts, record-keeping.

Trade surveillance & market-conduct playbooks

Trade surveillance & market-conduct playbooks — Dubai-aligned.

Ops & tech hygiene

Ops & tech hygiene — wallet governance, key ceremonies, incident response, BCP/DR.

Board reporting & attestations

Board reporting & attestations — ongoing evidence pack for inspections.

Ready to formalise your Dubai prop-trading set-up?

Book a Strategy CallRequest the Proprietary Trading Readiness Checklist