The Exchange Services licence is VARA's most demanding category — and the one that opens the widest market. We've done this before. We manage the full process so you can focus on your product.
Token listing approval - only VARA-approved assets may be listed; new listings require separate application
Custody decision - hold client assets in-house (requires Custody licence) or use a VARA-licensed custodian
Most applicants underestimate the technology audit requirement. VARA's Technology and Information Rulebook sets detailed standards for system resilience, cybersecurity, data integrity, and business continuity - a third-party auditor must verify compliance before the licence is issued.
What We Do for You
Activity classification
Confirm Exchange Services is the right category. OTC desks and market makers often qualify as Broker-Dealer - misclassification leads to over-capitalisation and delays.
Capital structure
Advise on optimal capital holding (trust account vs surety bond) and whether a VARA-licensed custodian reduces your capital requirement.
Technology audit preparation
Identify gaps in your tech stack before the auditor does. We prepare you for the mandatory third-party audit.
Market conduct framework
Design your market surveillance procedures, abuse detection policies, and incident reporting protocols per VARA's Market Conduct Rulebook.
Map your initial asset list against VARA's approved list; prepare token listing applications for assets not yet approved.
End-to-end ATI and VASP application
Full documentation package, VARA submission, and regulator engagement throughout review.
Regulated Activities in ADGM
VARA Crypto Brokerage Licensing (Dubai)
/vara-license-dubai
VA Proprietary Trading Launch (DMCC)
/dmccllicense
Frequently Asked Questions
Typically 6–10 months - longer than other VARA categories due to the technology audit requirement. Timeline depends heavily on how prepared your tech stack is when we begin.
Yes, unless you use a VARA-licensed third-party custodian. Using a custodian also reduces your minimum capital from AED 1.5M to AED 800K - a significant difference for most applicants.
Only VARA-approved virtual assets. Anonymity-enhanced tokens are prohibited. New listings require a separate VARA token listing application. We map your planned asset list against VARA's approved list as part of pre-application strategy.
Yes. The VARA licence covers your Dubai-incorporated entity. Cross-border operations are subject to the regulatory requirements of each jurisdiction you serve - we map this as part of the licensing strategy.
Start Your Launching a Regulated Crypto Exchange in Dubai Process
By submitting this form, I acknowledge that I have read and agree to the Privacy Policy, and I consent to the processing of my personal data.
Please note: We do not provide any personalized investment advice, token selection guidance, or transaction recommendations. AMLzone is a compliance consultancy and project management services provider, not a Virtual Asset Advisor.