Applying for the Transfer and Settlement Services Licence from VARA 

In the rapidly evolving landscape of virtual assets, regulatory compliance is paramount for entities looking to engage in transfer and settlement services. The Dubai Virtual Assets Regulatory Authority (VARA) sets stringent standards to ensure a robust and secure digital asset environment. This article provides a brief guide on how to apply for a Transfer and Settlement Services license from VARA, detailing the legal requirements, necessary compliance measures, and essential roles required for licensing. 

  1. General Compliance Requirements. 
  • Licensing Application: 

Entities must begin by preparing a detailed licensing application. This application should include a comprehensive business plan, risk assessments specific to the nature of the virtual assets handled, and evidence of initial compliance with VARA’s regulatory framework. The business plan should clearly outline the operational structure, intended services, target markets, and financial projections. 

  • Policies and Procedures: 

Applicants must establish robust internal policies and procedures that address several critical areas: 

  • Risk Management: Implement frameworks that identify, assess, manage, and monitor potential risks associated with virtual asset transactions. 
  • Operational Controls: Develop procedures that ensure efficient and secure operations, including transaction handling, client asset protection, and system integrity. 
  • Cybersecurity: Create comprehensive cybersecurity policies that safeguard digital and physical assets against unauthorized access and cyber threats. 
  • Data Protection: Ensure compliance with applicable data protection laws, particularly if handling sensitive or personal client data. 
  • Regular Audits and Reporting:  

Regular internal and external audits are crucial for maintaining ongoing compliance with VARA regulations. Entities must report the outcomes of these audits to VARA and provide regular updates on any significant operational changes or compliance-related incidents. 

  1. Mandatory Roles for Compliance: 

To ensure adherence to VARA’s regulations, certain key compliance roles must be filled: 

  • Chief Compliance Officer (CCO): The CCO oversees all compliance aspects within the entity, ensuring adherence to laws, regulations, and internal policies. This role is crucial in maintaining the integrity of the compliance program and training staff on compliance-related issues. 
  • Money Laundering Reporting Officer (MLRO): The MLRO is responsible for monitoring and reporting any suspicious money laundering activities. This role is integral to the entity’s AML/CFT compliance efforts, involving detailed record-keeping and reporting of suspicious activities to VARA. 
  • Chief Information Security Officer (CISO): The CISO manages all aspects of cybersecurity risk. Responsibilities include developing and enforcing cybersecurity policies, managing data protection strategies, and responding to cybersecurity incidents. 
  • Data Protection Officer (DPO): If the entity handles significant amounts of sensitive data, appointing a DPO is recommended. The DPO ensures compliance with data protection laws, manages data protection strategies, and conducts privacy impact assessments. The CISO can also be the DPO.  
  1. Specific Compliance Areas. 
  • Technology and Risk Management: Entities must implement a technology governance framework that addresses the generation and management of cryptographic keys, VA Wallets, and overall cybersecurity. 
  • Client Asset Protection: Robust controls must be established to protect client assets. These controls should ensure proper authorization and verification processes for all transactions to prevent unauthorized access and misuse. 
  • Market Conduct and Fairness: Entities are required to adhere to VARA’s market conduct rules. This includes ensuring transparency, fairness in client dealings, and proper management of any conflicts of interest. 

Applying for a Transfer and Settlement Services license from VARA involves a detailed understanding of the regulatory requirements and a commitment to maintaining high compliance standards. Entities must not only prepare comprehensive documentation and policies but also ensure they have the right team in place to manage compliance effectively. Adhering to these guidelines will facilitate a smoother application process and contribute to the establishment of a trustworthy and secure virtual asset environment in Dubai. 


As the leading legal advisory firm for Blockchain, Web3, and Crypto startups in the UAE, we provide unmatched professional legal advice to navigate the evolving regulatory landscape of digital assets and the licensing process of the Virtual Assets Regulatory Authority (VARA) of Dubai. From legal structuring, company registration to handling intricate legalities of token launch, NFTs and tokenization, our dedicated team ensures your ventures thrive without any regulatory issues. Dive deeper into how we can empower your blockchain ambitions—visit today and partner with us to revolutionize your projects! 


The article is provided solely for educational and informational purposes and does not, under any circumstances, constitute legal, financial, or tax advice. The information herein is not intended to serve as a substitute for professional consultation. Readers are strongly encouraged to engage the services of competent professionals in the legal, financial, or tax fields to obtain advice pertinent to their specific situation before undertaking any action based on the content of this article. 

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