VARA Broker-Dealer Services Rulebook (version dated 19 May 2025)chapter by chapter

Part I.A.1-2Part I.A Policies and procedures

VASPs must maintain written policies on market offences and abusive practices, order execution and routing, client access and withdrawals including during volatility, reviewed at least yearly.

Part I.B.1-3Part I.B Public disclosures

Broker-dealer must publish conflicts of interest, privacy, whistleblowing and complaints policies, per-token disclosures, price determination, routing practices, and referral arrangements, including liquidity sources receiving 20% or more of orders.

Part II.A.1-5 Best execution

VASPs must use reasonable diligence to achieve best execution of client orders on price, cost, speed, likelihood, size and nature, and bear the burden of proof for off-market execution.

Part II.A.6-7 Fee disclosure and no routing benefits

VASPs must disclose fees or commission retained from client payments before execution and in trade confirmations, and may not accept routing discounts or execution benefits, except necessary service fees.

Part II.A.8-16 Execution governance

Best execution cannot be delegated, and VASPs routing orders automatically or internalising order flow must review execution quality at least quarterly and notify clients of material changes.

Part II.B.1-2Part II.B Dealing as principal

VASPs may deal as principal, including riskless principal, subject to best execution, but may not use client money or virtual assets unless expressly permitted.

Part II.C.1Part II.C Advisory Services by broker-dealers

Broker-dealers may provide advisory services only if they hold a Broker-Dealer Licence, meet additional capital and prudential requirements for advisory services, and comply with the Advisory Services Rulebook.

Part III.A.1-3Part III.A Margin Trading authorisation

Margin trading may be offered by broker-dealers only when explicitly authorised by VARA and stated in the licence, and they must hold sufficient assets to meet client obligations at all times.

Part III.B.1-3Part III.B Margin Trading approval and powers

Margin trading approval requires submitting terms, a template margin agreement, financial condition and margin policies, and liquid collateral; VARA may inspect systems and order suspension, position close-out or higher margins.

Part III.C.1.a-lPart III.C Margin Trading obligations

Margin trading brokers must assess suitability, segregate accounts, monitor clients, issue monthly statements, give margin warnings, sell assets if margin is not restored, and keep records eight years.

Part III.D.1-3Part III.D Margin prudential limits

Single-client margin credit may not exceed one tenth of margin trading funds; retail initial margin must be at least twenty percent of notional position value.

Part III.E.1-2Part III.E Margin Trading Agreement

The Margin Trading Agreement must outline responsibilities, rights, and risks, requiring client consent and potential amendments by VARA.

Part IV.A.1-3Part IV.A Licensed Distribution Services scope

Broker-dealers providing licensed distribution services must comply with Part IV, which prevails over conflicting rules, and VARA may order suspension or cessation of specified virtual assets, issuers or clients.

Part IV.B.1-5Part IV.B Distribution due diligence

VASPs must conduct due diligence on each Issuer and Virtual Asset, including whitepaper, risk disclosure, smart contract audits and investor classification, and include the prescribed VARA disclaimer in documents.

Part IV.C.1-2Part IV.C Relationship with Issuer

Virtual asset broker-dealers must have written client agreements with each issuer and written controls to prevent, manage and disclose conflicts of interest, including initial placement pricing.

Part IV.D.1-7Part IV.D Submissions to VARA and Submission Period

Before distribution, a VASP must submit its whitepaper, risk disclosure statement, signed compliance declaration and due diligence reports, then wait a fifteen working day submission period.

Part IV.E.1-3Part IV.E Ongoing obligations and notification

VASPs must keep due diligence current throughout service, suspend or cease distribution when a Virtual Asset no longer complies, and repeat due diligence and resubmit after material changes.

Part III.C.1.l-retRecord Retention — Margin Trading service records

Broker-dealers must retain margin trading service records for eight years from the date of each record.