Dubai Law No. (4) of 2022 and related regulationschapter by chapter

Article 15(a)-(d)Article 15 - Conducting the Activity

No person may conduct a virtual asset activity in the emirate without a VARA permit, and must set up in an approved legal form and obtain approvals before commercial licensing.

Article 16(a)-(d)Article 16 - Activities Requiring Permits

Seven categories of virtual asset activity, including platform operation, exchange, transfer, safekeeping and wallet services, require a VARA permit, and VARA may add activities.

Article 17 - Assignment of Permits

A permit may not be assigned to another party without prior VARA approval under Director General rules; unapproved assignments are null and void.

Article 20(a)-(b)Article 20 - Violations and Administrative Penalties

VARA may suspend a Permit for up to six months or revoke it, coordinating commercial licence cancellation, for violations of the Law and its resolutions.

Article 22 - Grievances

Affected parties may submit a written grievance against VARA decisions within 30 days of notice; the committee decides within 15 days, and its decision is final.

Article 23(a)Article 23 - Cooperation with VARA

All persons, including VASPs, must fully cooperate with VARA, provide required information and documents, and must not obstruct VARA in exercising its functions and powers.

Article 4.1-4.4Article 4 - General Provisions (Licensing)

Anyone conducting virtual asset activities in the UAE must first obtain approval and licence from SCA or VARA, and dealing with unlicensed virtual asset providers is prohibited.

Article 7.1-7.2Article 7 - Minimum Licensing Requirements

Licence applicants and their partners must not be on sanctions or terrorism watchlists or under criminal investigation, and VASPs must meet capital, AML/CFT, cybersecurity and risk disclosure requirements.

Article 8 - AML/CFT Compliance

All virtual asset service providers in the UAE must comply with anti-money laundering and counter-terrorist financing legislation and the implementing decisions issued under it.

Article 14 - Adjustment of Situation (Transitional)

Virtual asset service providers licensed before the Decision took effect must meet its conditions and operational requirements within three months, subject to Authority-granted extensions.

Regulation I.B.1-4General Prohibitions - Licensed Marketing Only

Marketing of virtual assets targeting the UAE must follow marketing rules and be carried out only by VARA-licensed VASPs or approved persons; anonymity-enhanced cryptocurrency marketing is prohibited.

Regulation I.C.2General Marketing Content Requirements

All marketing must be fair, clear, not misleading and identifiable as promotional, must not contradict mandated risk warnings or imply guaranteed returns, and must disclose paid third-party content.

Regulation I.C.3Virtual Asset-Specific Marketing Requirements

Virtual Asset marketing must not include buy or sell calls, must carry a prominent disclaimer on value loss and volatility, must warn investors they can lose everything without financial protection, and no unsolicited wallet transfers.

Regulation I.C.4Marketing Record Keeping

Entities marketing virtual assets or VA activities targeting the UAE must keep records of all marketing and its distribution for eight years from last marketing, available for VARA inspection on request.

Regulation I.C.5Marketing Agency Arrangements

Makes an instructing entity responsible for a third-party marketing agency's compliance with marketing rules, requiring the agency to take reasonable compliance steps, obtain approval before marketing, and bear liability for its own breaches.

Regulation I.E.1-4Platforms, Channels and Application Stores

Platforms facilitating marketing, such as broadcasters, publishers, search engines and social media, must take commercially reasonable steps to ensure compliant marketing and keep due diligence records for eight years.

Regulation I.F.1-2Events in the Emirate

Non-Licensed Entities can market at Emirate events under specific conditions, requiring event organisers to vet attendees and prevent unlicensed VA Activities.

Regulation I.G.1Marketing From the Emirate Into Other Jurisdictions

Entities in the Emirate must adhere to all external marketing laws and regulations when marketing outside the Emirate.

Regulation I.B.3.cRules, Directives and Guidance - Non-Disclosure of Directives

Entities and VASPs must not publish or publicise details of any VARA Directive, in whole or part, before VARA has made it public on its website, unless VARA otherwise specifies or permits.

Regulation I.C.4-retRecord Retention — Marketing content and distribution records

Marketing content and distribution records must be retained for 8 years from the date the marketing was last conducted.

Regulation I.E.2-retRecord Retention — Platform/channel due diligence records

Platform and channel due diligence records must be retained for 8 years from the date the due diligence was completed under VARA record retention requirements.

Regulation II.A.1Issuance Rules

Entities issuing virtual assets in the Emirate must adhere to the VA Issuance Rulebook.

Regulation II.A.1-2; Schedule 1Enforcement and Fines

Violations of Marketing Regulations incur fines ranging from AED 500,000 to AED 10,000,000, with increased penalties for repeat offenses.

Regulation III.A.1-3General Prohibition and Exemptions

No entity may conduct virtual asset activities by way of business in the Emirate without VARA licensing, employee status under a licensed employer, or exempt status, and unlicensed entities must not claim VASP status.

Regulation IV.A.1-4Requirement to Hold and Maintain a Licence

Entities conducting virtual asset activities in the Emirate must obtain VARA authorisation and a licence for each activity, comply with licensing conditions, and meet the higher standard when operating abroad.

Regulation IV.A.6Exempt Entity Notification and No-Objection

Exempt Entities must notify VARA and obtain confirmation of exempt status, get VARA no-objection before any VA Activities, and comply with all no-objection conditions.

Regulation IV.A.7Mandatory Registration for Large Proprietary Traders

Any Entity in the Emirate investing its own portfolio in Virtual Assets at or above USD 250,000,000 equivalent in a rolling thirty-day period must register with VARA, before or within three Working Days.

Regulation IV.A.8Voluntary Registration for Other Market Participants

DLT technology service providers and entities investing their own portfolios below the mandatory threshold may voluntarily register with VARA, but registration does not authorise any virtual asset activity.

Regulation IV.B.2Licence Variation, Suspension or Revocation Grounds

VARA may vary, suspend or revoke a licence for material legal violations, good cause, insolvency, or unpaid final court judgments within 30 days; suspended VASPs need prior approval to resume.

Regulation IV.B.4; Schedule 2Authorisation and Supervision Fees

VASPs must pay licence application, extension, and annual supervision fees in advance of each Licensed VA Activity, and VARA may impose extra supervision fees based on risk profile.

Regulation IX.A.2-3; IX.B.1-7Cooperation, Examination and Post-Deregistration Tail

Entities must cooperate with VARA investigations, provide requested information, and remain subject to regulations for ten years post deregistration.

Regulation IX.A.3-retRecord Retention — Post-deregistration regulatory tail (continued applicability of Regulations/Rule

Regulations, rules and directives continue to apply to former VASPs and issuers for ten years after VARA deregistration.

Regulation V.1-2Mandatory Rulebook Compliance

VASPs must at all times comply with the four core rulebooks and with each VA-activity-specific rulebook corresponding to their licensed activities, such as custody, exchange or lending services.

Regulation VI.B.1AML/CFT Obligations of VASPs

VASPs must comply with all federal AML-CFT laws and other AML/CFT regulatory requirements applicable to their virtual asset activities in any jurisdiction, including FATF recommendations incorporated by VARA.

Regulation VIII.E.1Prohibition of Insider Dealing and Unlawful Disclosure

Virtual asset entities are prohibited from insider dealing, inducing others to insider deal, and unlawfully disclosing inside information outside normal employment or professional duties.

Regulation VIII.G.2-4, 7Market Sounding Obligations

Before a market sounding, a disclosing entity must assess inside information risk, document conclusions, obtain recipient consent, warn of trading restrictions, and keep records for eight years.

Regulation VIII.I.1Prohibition of Market Manipulation

No entity may engage or attempt market manipulation, including false signals, artificial prices, fictitious devices, false benchmark inputs, or distributing manipulation software, unless an accepted practice applies.

Regulation VIII.J.1-4Prevention, Detection and Reporting of Market Offences

VASPs must maintain arrangements to prevent and detect market offences, report suspicious activity to the UAE FIU and VARA with required details, and make relevant data available to VARA on request.

Regulation VIII.G.7-retRecord Retention — Market Sounding assessment, consent and disclosure records

Market Sounding assessment, consent, and disclosure records must be retained for 8 years from the date of each disclosure.

Regulation X.A.1-2Duty of Confidentiality

All Entities must keep confidential all information relating to VARA's operations and communications, and ensure employees and contractors with access are bound by equivalent confidentiality obligations.

Schedule 2 para 1 (Advisory Services)Schedule 2 para 1 - Advisory Services fees

Advisory services providers under the VARA regime pay an AED 40,000 licence application fee for one regulated virtual asset activity and an AED 80,000 annual supervision fee per activity.

Schedule 2 para 1 (Broker-Dealer Services)Schedule 2 para 1 - Broker-Dealer Services fees

Broker-Dealer Services licence application fee is AED 100,000 for one regulated VA activity; annual supervision fee is AED 200,000 for each regulated VA activity.

Schedule 2 para 1 (Category 1 VA Issuance)Schedule 2 para 1 - Category 1 VA Issuance fees

Applicants for Category 1 VA issuance must pay an AED 100,000 licence application fee for one regulated activity and an AED 200,000 annual supervision fee for each regulated activity.

Schedule 2 para 1 (Custody Services)Schedule 2 para 1 - Custody Services fees

Custody services providers face an AED 100,000 licence application fee for one regulated VA activity and an AED 200,000 annual supervision fee for each regulated VA activity.

Schedule 2 para 1 (Exchange Services)Schedule 2 para 1 - Exchange Services fees

Exchange Services applicants pay an AED 100,000 licence application fee for one regulated VA Activity, and an AED 200,000 annual supervision fee for each regulated VA Activity.

Schedule 2 para 1 (Lending and Borrowing Services)Schedule 2 para 1 - Lending and Borrowing Services fees

Lending and Borrowing Services under VARA require an AED 100,000 licence application fee for one regulated VA Activity and an AED 200,000 annual supervision fee per regulated VA Activity.

Schedule 2 para 1 (Licence Extension Fee)Schedule 2 para 1 - Licence Extension Fee

The Licence Extension Fee for each additional regulated VA Activity equals 50% of the lower of the applicable Licence Application Fees.

Schedule 2 para 1 (VA Management and Investment Services)Schedule 2 para 1 - VA Management and Investment Services fees

VA management and investment services providers must pay a AED 100,000 licence application fee for one regulated VA activity only, and a AED 200,000 annual supervision fee for each regulated VA activity.

Schedule 2 para 1 (VA Transfer and Settlement Services)Schedule 2 para 1 - VA Transfer and Settlement Services fees

VA Transfer and Settlement Services licence application fee is AED 40,000 for one regulated VA activity, and annual supervision fee is AED 80,000 per regulated VA activity.

Schedule 2 para 2-3 - Timing of fees

Licence application and extension fees are payable only upon submission of the VA licence application, which is not processed until paid; the Annual Supervision Fee must be paid in advance of conducting each licensed VA Activity.

Schedule 2 para 4-6 - Additional and discretionary fees

VARA can impose additional supervision fees based on a VASP's characteristics and may charge fees for virtual asset issuance approvals.