CRYPTO EXCHANGE SERVICES — BUILD A FAIR, LIQUID, ALWAYS-ON TRADING VENUE
We help VASPs launch and scale VARA-compliant crypto exchanges, governance that satisfies Boards, surveillance that reassures regulators, and disclosures your users can trust.
Advising order-book venues, conversion rails, and hybrid OTC–venue models on VARA-tight controls and filings.
WHAT THE VARA EXCHANGE LICENCE COVERS
Under VARA’s Regulations, Exchange Services include:
Exchanging Crypto ↔ Fiat
Exchanging Crypto ↔ Crypto
Matching orders and conducting those exchanges
Maintaining an order book for the above
Note: The Exchange Services Rulebook (ESR) applies in addition to the four Compulsory Rulebooks: Company, Compliance & Risk Management, Technology & Information, and Market Conduct (cumulative obligations).
SERVICES YOU CAN OFFER UNDER THIS LICENCE
Order-book spot exchange (crypto↔fiat; crypto↔crypto)
Operate a central order book, admit participants, and enforce a published code of conduct with a full disciplinary toolkit (warnings, suspensions, expulsions, order cancellations, criminal referrals). Client acceptance of venue rules must be captured in the Client Agreement.
Market surveillance & regulator notifications
Share surveillance information with VARA and, where abuse is suspected, notify on large positions, inventory, position-limit actions, margin calls, and steps taken.
Transparent, fair, non-discriminatory fees
Fee structures must not incentivise manipulative order activity (e.g., place/modify/cancel loops that disrupt orderly markets).
COMPLIANCE GUARDRAILS THAT KEEP YOU OUT OF TROUBLE
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Board governance. |
At least one independent director; quarterly Board meetings; Remuneration, Nomination, Audit committees; 8-year minute retention; annual Board remuneration reporting to VARA. |
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AML/CFT suite |
Business & client risk-assessment templates (≤3-month cadence), CDD/PEP/ECDD SOPs, STR runbooks, Travel-Rule policy with sunrise approach. |
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Client Money/Client VA packs |
Bank acknowledgments, Client Account SOPs, daily recon workpapers, Client VA 1:1 wallet labelling, PoR documentation. |
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AB&C programme |
Policy, hotline workflow, investigation file templates, training. |
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Sponsored VASP kit |
Sponsor agreement, governance/MI, RO approvals, disclosures. |
What CRYPTOVERSE Legal delivers
Licensing strategy & submissions
Activity mapping, exchange model selection, Board/committee charters, cumulative-rulebook matrix, prudential readiness.
Venue Rulebook pack
Trading code of conduct, participant eligibility, disciplinary matrix, Client-Agreement inserts (venue rule acceptance).
Market-surveillance program
Alerts, large-position reporting, abuse scenarios, notification playbooks, and evidence packs.
Price-formation & disclosure suite
Pricing methodology note (inputs, fallbacks), per-asset disclosure templates, custody/clearing copy, fee-transparency language.
Tech & resilience controls
Capacity sizing, pre-trade blocks/kill-switches, BCP/DR runbooks, periodic continuity tests.
Settlement discipline
T+0 workflows; exception handling for external network constraints.
Margin-trading enablement (if endorsed)
VARA approval dossier, Margin Agreement, collateral policy, prudential caps, alert & liquidation playbooks, monthly statem
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.
Why CRYPTOVERSE Legal
Venue specialists
Venue specialists who translate ESR clauses into practical operating playbooks.
Evidence-ready controls
Evidence-ready controls mapped clause-by-clause to ESR + Compulsory Rulebooks.
Speed with substance
Speed with substance—we compress timelines without cutting compliance corners.
Speak to a Crypto Lawyer
Book a Strategy CallFAQs
Yes — full-time, UAE-resident/UAE-passport, VARA-approved; changes require approval (with emergency notice allowances)
Yes, but the individual remains accountable to VARA; VARA can require in-house staffing.
NLA ≥ 1.2× monthly opex, plus activity-based PUC, mandated insurance, and reserves = 100% 1:1 same VA.
Anything that could significantly affect the model/operations/VA activities or compliance posture (incl. scope changes, control shifts) — needs prior approval.