VARA - NOC
Crypto Regulations in Dubai: Navigating VARA, NOC Requirements, and Proprietary Trading Compliance
Everything You Need to Know to Launch a Successful Business in the UAE
Dubai has rapidly emerged as a leading global hub for virtual assets, thanks to its progressive regulatory environment and the establishment of the Virtual Assets Regulatory Authority (VARA). As more crypto companies look to set up in the UAE, understanding the nuances of local regulation — especially around NOC (No Objection Certificate) requirements and proprietary trading activities — is crucial for maintaining compliance and business continuity.
Understanding VARA’s Role in Dubai’s Crypto Ecosystem
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.
What is a NOC from VARA — And Who Needs It?
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: Is a License Required?
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.
VARA’s Enforcement Is Real — and Expanding
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.
How Proxima Eight Can Help
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.
Want to stay ahead of Dubai’s crypto compliance curve?
Contact AML Zone today for a private consultation.
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.
What is a NOC from VARA — And Who Needs It?
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: Is a License Required?
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.
VARA’s Enforcement Is Real — and Expanding
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.
How Proxima Eight Can Help
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.
Want to stay ahead of Dubai’s crypto compliance curve?
Contact AML Zone today for a private consultation.