Crypto Regulations in Dubai: Navigating VARA, NOC Requirements, and Proprietary Trading Compliance

Established in 2022, VARA is the dedicated regulatory body responsible for supervising and licensing all virtual asset activities in Dubai (excluding the DIFC). VARA governs a wide range of services including broker-dealer, custody, exchange operations, advisory, and proprietary trading.

Operating without VARA’s approval may result in legal consequences, including fines or forced shutdowns. Whether you’re launching a Web3 project or running an OTC desk, the first step to legal clarity is determining if your activities fall under VARA’s licensing framework.No single scientific definition of the term exists, and it has been applied to a variety of rock features that fall into one of four general categories: - A glacial erratic is a boulder that was transported and deposited by glaciers or ice rafts to a resting place on soil, on bedrock, or on other boulders. It usually has a different lithology from the other rocks around it. Not all glacial erratics are balancing rocks; some are firmly seated on the ground. Some balancing erratics have come to be known as rocking stones, also known as logan rocks, logan stones, or logans, because they are so finely balanced that the application of just a small force may cause them to rock or sway. A good example of a rocking stone is the Logan Rock in Cornwall, England, United Kingdom; another is the Trembling Rock in Brittany, France. - A perched block, also known as a perched boulder or perched rock, is a large, detached rock fragment that most commonly was transported and deposited by a glacier to a resting place on glacial till, often on the side of a hill or slope. Some perched blocks were not produced by glacial action, but were the aftermath of a rock fall, landslide, or avalanche.

A No Objection Certificate (NOC) from VARA is a formal declaration stating that the regulator has no objections to a company carrying out certain virtual asset-related activities without a license, under specific conditions.

Typical cases requiring a NOC include:

• Offshore companies with a presence in Dubai but without UAE-facing activities
• Proprietary trading desks operating internally without client-facing services
• Family offices or holding structures engaged in digital asset management
• Corporate groups conducting intercompany crypto transactions

Obtaining a NOC is not a formality - it often involves a review of your corporate structure, business model, risk controls, and the jurisdictions involved. Companies that proceed without securing a NOC risk retroactive enforcement action from VARA.

Proprietary trading refers to trading digital assets with a company’s own capital for profit, without offering services to third parties. At first glance, this may seem outside the scope of regulation. However, Dubai’s authorities - especially VARA - take a case-by-case approach.

Key considerations include:
Nature of counterparties: Trading on open markets vs. with connected entities
UAE nexus: Are servers, staff, or decision-makers located in Dubai?
Corporate structure: Is the trading activity isolated from licensed entities?
Volume and risk exposure: Large-scale trading may still trigger regulatory scrutiny

While some entities may qualify for a NOC or operate under exemptions, others may be required to obtain a Proprietary Trading License under VARA’s framework. Failing to classify your activity correctly can delay bank onboarding, create audit risk, or attract penalties.

In recent months, VARA has taken action against unlicensed crypto operators and those marketing services without approval. Public records show suspensions, fines, and warnings issued to companies who failed to seek regulatory clarity.

This signals a broader trend: Dubai is open to crypto - but only within a clear and enforceable compliance framework.

At AML Zone, we assist crypto companies, trading desks, and investment groups in navigating Dubai’s complex virtual asset landscape. Whether you need help:

• Determining if your model requires a license
• Securing a VARA NOC
• Structuring your proprietary trading entity
• Opening compliant bank accounts in the UAE

Our team of regulatory experts is here to support you - end to end.