VARA NOC for Proprietary Trading: What Crypto Trading Firms in Dubai Need to Know
Last updated: 21 October 2026
- A company that trades only its own virtual assets in Dubai does not need a VARA licence, but it needs a No Objection Certificate (NOC) before the first trade.
- Trading for relatives, partners or outside investors, or regularly trading at a counterparty’s initiative, is not proprietary trading and most likely needs a VASP licence.
- The NOC costs AED 1,000 a year under VARA’s 2023 fee guidance.
- Once 30-day rolling trading volume exceeds USD 250 million, the company must also register with VARA.
- A licensed VASP cannot trade for its own account or hold its group’s portfolio: proprietary trading needs a separate company with its own NOC.
“We only trade our own money. Why would VARA care?” We hear this from trading firms, family offices and founders who move their crypto activity to Dubai. The short answer is that VARA does care. A company that trades only its own virtual assets does not need a licence, but it does need a No Objection Certificate (NOC) from the Virtual Assets Regulatory Authority (VARA), and above a certain volume it must also register. Obtaining the NOC is usually straightforward. The real risk is that the business gradually stops fitting VARA’s definition of proprietary trading.
Read more: VARA NOC: When You Need One and When You Need a Licence
Read more: VARA NOC: When You Need One and When You Need a Licence
What VARA treats as proprietary trading
VARA’s FAQ describes proprietary traders as firms that trade their own funds and do not trade “as a service to friends-family and/or third-party mass market”, in other words, firms with no clients. Two limits follow from this wording.
- No outside money. Once a company trades for relatives, partners or any outside investors, it is no longer proprietary trading, however small the circle is.
- No trades at someone else’s initiative. VARA excludes deals where a company uses its own funds to buy or sell virtual assets with a third party “at the initiation of the third party”. A firm that regularly answers counterparties’ requests to buy or sell starts to look like a broker-dealer, and that is a licensed activity.
The NOC: required “at all times”, a licence not required “at this time”
VARA’s FAQ uses two phrases that are worth reading together. Proprietary trading must obtain an NOC “at all times”, while proprietary traders are not required to hold a VARA licence “at this time”. The first means that the NOC must be in place before the first trade. The second describes VARA’s current approach, not a permanent exemption. Under VARA’s 2023 fee guidance, the NOC costs AED 1,000 a year. It covers trading with the company’s own funds only and does not allow it to serve clients or hold third-party assets.
Registration above USD 250 million
An NOC on its own is enough only up to a certain volume. Once the company’s cumulative 30-day rolling trading volume exceeds USD 250 million (VARA’s FAQ also refers to AED 1 billion), it must register with VARA and becomes subject to regulatory oversight. This applies “regardless of whether it is being undertaken as a business”, so holding companies and family offices that actively trade a crypto treasury are covered too. There is no additional fee for the registration itself.
Already licensed? Use a separate company
A licensed VASP is prohibited from trading for its own account, and the ban goes further than many expect: VARA bars licensed VASPs from “proprietary trading or trading their Group’s portfolio of assets” and requires a separate company to be set up for proprietary trading. In practice, this means that a group treasury cannot sit inside the licensed entity either. The trading company needs its own NOC, and its accounts and operations should be kept apart from the licensed business.
How to apply
The application is made through VARA Connect, VARA’s online portal, where the applicant completes the Initial Disclosure Questionnaire (IDQ) with information about the company, its owners and the proposed trading activity. The commercial licensor, such as Dubai Economy and Tourism (DET) or a free zone like DMCC, remains part of the process: VARA states that firms seeking a proprietary trading NOC need to contact their commercial licensors.
Where firms go wrong
The typical problem is not bad intent but a business model that changes step by step. A partner asks to “put in some money”. A counterparty starts placing regular orders. The licensed company and the trading company share one account. Each of these steps can turn an NOC business into one that needs a licence. VARA does enforce the line: in October 2025 it fined 19 firms between AED 100,000 and AED 600,000 for unlicensed activity and marketing breaches and ordered them to stop operating.7
What we recommend
- Describe the business model on one page: whose money is traded, with whom and on whose initiative. Revisit it whenever a new investor, counterparty or service appears.
- Track the 30-day rolling volume from day one and plan registration well before it reaches the threshold.
- If your group includes a licensed VASP, place proprietary trading and the group treasury in a separate company from the start.
The bottom line
For a firm that really trades only its own money, the VARA NOC is a simple and inexpensive way to work legally in Dubai. The risk is not in getting it, but in outgrowing it without noticing. AMLzone can review your trading model against VARA’s definitions and thresholds and prepare the NOC application with your licensor.
Sources
1. VARA, “VARA Publishes Clarification and Further Information on Fees”, 22 June 2023. https://www.vara.ae/en/news/vara-publishes-clarification-and-further-information-on-fees/
2. VARA, “Licensed Activities”. https://www.vara.ae/en/licenses-and-register/licensed-activities/
3. VARA, “VARA Steps Up Enforcement to Safeguard Dubai’s Virtual Asset Market: 19 Unlicensed Firms Penalised and Public Warning Issued”, 7 October 2025. https://www.vara.ae/en/regulations/regulatory-notices/vara-steps-up-enforcement-to-safeguard-dubai-s-virtual-asset-market-19-unlicensed-firms-penalised-and-public-warning-issued/
22.10.2026
