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
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
Trade your treasury/house book
Trade your treasury/house book across approved venues or OTC on your own account only.
Deploy liquidity
Deploy liquidity to strategies consistent with your board-approved policy (spot, basis, hedges).
Operate wallets & controls
Operate wallets & controls for firm assets (no client commingling).
Outsource execution/prime
Outsource execution/prime on arm’s-length terms (with diligence and audit rights).
No client services
No client services (no brokerage, exchange operation, custody, lending/borrowing, management/advice).
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.