VARA BROKER-DEALER SERVICES — END-TO-END LICENSING, EXECUTION & COMPLIANCE
Launch and scale a VARA-ready brokerage, OTC desk, or market-making operation in Dubai — with bulletproof governance, Best-Execution controls, and public disclosures that pass scrutiny.
Advising order-book venues, conversion rails, and hybrid OTC–venue models on VARA-tight controls and filings.
WHAT THE VARA BROKER-DEALER LICENCE COVERS
Under VARA, Broker-Dealer Services let a VASP:
Arrange orders to buy/sell Virtual Assets between two entities.
Solicit/accept client orders and take fiat or VAs to execute those orders.
Facilitate matching between buyers and sellers (including OTC).
Enter trades as principal (own account).
Make markets (subject to strict client-asset rules — see “Compliance Guardrails”).
Provide placement, distribution, or other issuance-related services for clients issuing VAs (“Licensed Distribution Services”).
Good to know: The Broker-Dealer Rulebook sits on top of VARA’s core framework — Company, Compliance & Risk, Technology & Information, and Market Conduct rulebooks — and applies cumulatively.
SERVICES YOU CAN OFFER UNDER THIS LICENCE
Agency broking & execution-only order handling
Execute client orders across multiple liquidity sources with a documented Best-Execution standard that weighs price, costs, speed, likelihood of execution/settlement, size and order specifics.
Principal dealing & market-making
Deal as principal (including riskless principal) to satisfy client orders, manage inventory, and support placements — while still meeting Best-Execution standards. Never use Client Money/Client VAs except where expressly permitted under VARA’s Compliance & Risk framework.
Matching & OTC execution
Facilitate off-Market fills with other VASPs/third parties — you keep the burden to evidence Best-Execution on every trade.
Licensed Distribution Services (placements/issuances)
Act for issuers on placements and distributions, subject to issuer/asset due diligence, mandated disclaimers, and a 15-Working-Day Submission Period before distribution may begin.
Advisory Services (optional add-on)
A Broker-Dealer VASP may also provide Advisory Services in Dubai if it keeps the BD licence in good standing and complies with the Advisory Services Rulebook and any extra capital/prudential requirements.
Margin Trading (optional add-on)
Provide margin services only if your licence expressly authorises it and your systems, policies, and client-protection measures meet VARA’s Part III standards.
COMPLIANCE GUARDRAILS THAT KEEP YOU OUT OF TROUBLE
|
Best-Execution is non-delegable. |
You can’t outsource the obligation; you must document venue selection (including thin/liquidity-stressed markets), and review execution quality at least quarterly if you internalise or route flow |
|
No “pay-for-order-flow.” |
You must not take cash/benefits for routing orders to a venue or entity; fee structures must avoid execution conflicts. |
|
Client assets are sacrosanct. |
Even when dealing as principal, do not use Client Money/Client VAs except as expressly permitted under Compliance & Risk. |
|
Public disclosures on your website. |
Publish your pricing approach, routing practices (flag any source ≥20% of client orders), custody/clearing arrangements, client-asset protections, introducer/referral terms, and any other items VARA may require. |
|
Distribution controls. |
Use the mandatory VARA issuer/asset due-diligence, include the VARA disclaimer in whitepapers and docs, and observe the Submission Period — no distribution before it ends, and you must address any VARA comments first. |
What CRYPTOVERSE Legal delivers
Licensing strategy & submissions
Activity mapping, RBP alignment, capital/prudential scoping, margin/advisory endorsements where applicable.
Best-Execution & routing framework
Policy, venue-selection logic, quarterly quality-of-execution review process, MI dashboards, and audit trail templates.
Conflict & inducement controls
PFOF prohibition, remuneration policies, order handling segregation, principal-vs-agency decisioning.
Public-disclosure pack
Website language covering pricing methodology, routing ≥20% disclosures, custody/clearing, client-asset protections, and introducer arrangements.
Distribution/placement suite
Issuer/asset due-diligence (incl. investor classification, whitepaper/RDS review, smart-contract audit verification), mandated disclaimers, and Submission-Period calendaring.
Margin-trading readiness (if endorsed)
Margin agreement, collateral eligibility, alerts/liquidation playbooks, suitability assessments, and VARA approval support.
OUR PROCESS (FAST & REGULATOR-READY)
Scoping call
model & activity mapping (order-book, conversion rails, margin).
Regulatory blueprint
Artefact list, Board/committee design, capital & prudential mapping.
Policy build-out
Market-abuse, withdrawals in stress, settlement/clearing, pricing methodology.
Tech & controls
Venue rules, surveillance, capacity & BCP/DR, erroneous-order threshold
Regulator interactionS
Notifications and submissions (surveillance, fee model, board reporting).
Go-live support
Public disclosures, periodic reviews, tabletop drills.
FAQs
Yes — principal fills are allowed, but you must meet Best-Execution and keep a defensible record.
No. PFOF and similar inducements are prohibited.
Pricing methodology, routing practices (including ≥20% destinations), custody/clearing, client-asset protections, introducer terms, among others.
A 15-Working-Day Submission Period starts after you file required materials; distribution can begin only after it ends and any VARA comments are resolved.
Yes, if you keep the BD licence in good standing and comply with the Advisory Services Rulebook and related capital/prudential requirements.
No. It’s an explicit authorisation on your licence, with standalone obligations and approvals.
Why CRYPTOVERSE Legal
Narrow-cast expertise
We live inside VARA’s trading, principal, distribution, and margin rules — so your controls read like they were drafted in-house.
Evidence-ready documentation
Every control is mapped to a rule and leaves a clear audit trail.
Speed with substance
We compress timelines without cutting corners — from policy stacks to website disclosures.