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Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates
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VARA Exchange Services Licence: Running a Regulated Crypto Exchange in Dubai
The Exchange Services licence authorises firms to operate a platform where buyers and sellers execute VA transactions. We manage the full application — from entity setup to licence approval.
9+ Years of Compliance Expertise
End-to-End Execution
What Is the VARA Exchange Services Licence?
Exchange Services authorises operating a platform that matches buy/sell orders or acts as counterparty to client VA transactions. This includes:
- Spot trading platforms (centralised exchange)
- Order-book exchanges
- Market-making platforms with internal matching
- Multilateral trading facilities for virtual assets
Capital Requirements
Structure
Paid-Up Capital
Using a VARA-licensed custodian
Higher of AED 800,000 or 15% of fixed annual overheads
Without VARA-licensed custodian
Higher of AED 1,500,000 or 25% of fixed annual overheads
Note: Capital held in UAE bank trust account with VARA as beneficiary, or as a surety bond. Multiple activities require capital for each separately.
Key Requirements
Responsible Individuals
Minimum 2 RIs — full-time employees, UAE residents or UAE passport holders, approved by VARA as Fit and Proper.
Technology audit
VARA's Technology and Information Rulebook requires a third-party technology audit before licence issuance. Covers system resilience, cybersecurity, data integrity, and business continuity.
Market conduct
Exchange operators must implement market surveillance, trade monitoring, and market abuse prevention procedures under VARA's Market Conduct Rulebook.
Token listing
Only VARA-approved virtual assets may be listed. Anonymity-enhanced tokens are prohibited. Privacy tokens and algorithmic stablecoins are not eligible.
Client classification
Retail, Professional, and Market Counterpart tiers must be implemented.
Custody
If you hold client assets, you need a separate Custody Services licence or must use a VARA-licensed custodian.
Physical presence
Private office in Dubai required.
What We Do for You
- Activity classificationConfirm Exchange Services is the right category. Many OTC and brokerage models qualify as Broker-Dealer rather than Exchange - misclassification leads to over-capitalisation and delays.
- Custody structuringAdvise on whether to use a third-party VARA custodian (lower capital) or apply for Custody Services.
- AML/KYC frameworkFull AML programme: policies, KYT integration, travel rule compliance, goAML registration.
- Technology audit preparationIdentify technology gaps and prepare your stack for VARA's third-party audit.
- Market conduct frameworkDesign your market surveillance and trade monitoring procedures per the Market Conduct Rulebook.
- Full ATI and VASP applicationEnd-to-end management.
Frequently Asked Questions
Only assets on VARA's approved list. Anonymity-enhanced tokens are prohibited. New token listings require a separate VARA token listing application.
Yes, unless you use a VARA-licensed custodian. Using a custodian also reduces your capital requirement from AED 1.5M to AED 800K.
Exchange operators run their own matching engine or act as counterparty. Broker-Dealers route client orders to external venues. If you don't run a matching engine, Broker-Dealer may be the right category.
Yes. Foreign group ownership is permitted. The licensed entity must be a UAE LLC or FZ CO with physical presence in Dubai.
Related
Start Your VARA Exchange Services Licence Process
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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.