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).
Trading systems continuity
Maintain resilient systems with sufficient capacity in high volatility, pre-trade controls (reject fat-finger/threshold breaches), and BCP/DR for trading and reporting continuity.
Settlement discipline
Complete final settlement within 24 hours (T+0) after execution on your venue, subject to external network limits.
Margin Trading (optional add-on)
Offer Margin Trading only if explicitly authorised on your Licence. Obligations cover: suitability, segregated margin accounts, collateral eligibility (financed crypto, fiat, USD/AED-referenced VA approved by VARA), Retail Initial Margin ≥ 20% notional, prudential caps (single-client credit ≤ 1/10 of funds allocated to margin), early-warning & breach alerts, liquidation playbooks, and 8-year recordkeeping.
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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Policies you must have |
Written policies for market-abuse prevention, client access/withdrawals even in extreme volatility, settlement/clearing, and price-formation methodology (data integrity); annual effectiveness review. |
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Public website disclosures (prominent) |
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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).
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.
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—both sit within Exchange Services, including maintaining an order book and matching orders.
No. It requires explicit licence endorsement and compliance with ESR Part IV (incl. Retail Initial Margin ≥ 20%).
Resilient systems, capacity in high volatility, pre-trade rejections, and BCP/DR are mandatory
Within 24 hours of trade execution on your venue, subject to external DLT limits.
Conflicts; privacy/whistleblowing/complaints; per-asset facts (incl. latest audit & largest drawdown); custody/protection; pricing method; plus Market Conduct & CRM items.
Fees must be transparent, fair, non-discriminatory and may not incentivise disruptive order activity.