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VARA Custody Services Licence: Regulated Virtual Asset Custody in Dubai
The Custody licence authorises safekeeping and administration of virtual assets on behalf of clients. It's technically demanding — and commercially valuable: a licensed custodian can serve other VARA-licensed firms.
9+ Years of Compliance Expertise
End-to-End Execution
What Is the VARA Custody Services Licence?
A VARA Custody licence authorises:
- Safekeeping client virtual assets (hot and cold wallet management)
- Administering VA holdings on behalf of institutional or retail clients
- Acting as qualified custodian for VARA-licensed Broker-Dealers, Exchanges, or Management firms
Capital Requirements
Structure
Paid-Up Capital
All cases
Higher of AED 600,000 or 25% of fixed annual overheads
Key Requirements
Responsible Individuals
2 RIs required — UAE residents, full-time, VARA-approved.
Physical presence: Private office in Dubai required.
Physical presence: Private office in Dubai required.
Asset segregation
Client assets must be fully segregated from firm assets at all times. VARA's Custody Rulebook sets requirements for wallet structure, key management, and segregation procedures.
Technology audit
Mandatory third-party technology audit. Covers cold/hot wallet ratios, key management, multi-signature requirements, cybersecurity, and disaster recovery.
Reserve attestation
VARA requires periodic attestation of reserves to confirm client assets are held 1:1.
Commercial Opportunity
A VARA Custody licence is not just a compliance requirement — it's a revenue line. Licensed custodians can:
- Provide custody to VARA-licensed Exchanges and Broker-Dealers who use a third-party custodian to reduce their own capital requirements
- Service VARA-licensed Management & Investment firms
- Offer institutional custody to corporates and family offices
What We Do for You
- Technology audit preparationPrepare your tech stack for VARA's mandatory third-party audit.
- Asset segregation frameworkPolicy and operational procedures for full client asset segregation.
- Insurance procurement guidanceRequirements mapping for crime and cyber coverage.
- Full AML/KYC and VASP applicationEnd-to-end preparation and submission.
- Custody model designCold/hot wallet structure, key management framework, third-party technology providers.
Frequently Asked Questions
Yes, if your exchange holds client assets directly. Alternatively, you can use a VARA-licensed third-party custodian — which also can reduce your Exchange capital requirement from AED 1.5M to AED 800K.
VARA's Technology and Information Rulebook sets requirements including cold/hot wallet ratios, multi-signature key controls, key ceremony (formal multi-party procedure for creating cryptographic keys for cold wallets) documentation, cybersecurity controls, and business continuity planning. A third-party technology audit is mandatory before licence issuance.
Yes. This is one of the main commercial use cases for a standalone Custody licence.
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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.
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.