UAE Virtual Assets Market
There are five primary licensing authorities in the United Arab Emirates (UAE) that regulate virtual assets and virtual asset services. These are the Dubai Virtual Assets Regulatory Authority (VARA), the Dubai Financial Services Authority (DFSA), the Financial Services Regulatory Authority (FSRA) of the Abu Dhabi Global Market (ADGM), the Dubai Multi Commodities Centre Authority (DMCC), and the Securities and Commodities Authority (SCA) of the United Arab Emirates (UAE). Each of these authorities has its own licensing regime and jurisdiction, and the requirements for licensing and the services that can be offered under each regime vary.
UAE Virtual Assets Market
We have compiled a comparison of the licensing regimes and the services that can be offered under each regime in the table below. This comparison is based on the information available through the respective authorities' websites and other publicly available sources. The information in this table is intended to provide a high-level overview of the licensing regimes and the services that can be offered under each regime. It is not intended to be a comprehensive or exhaustive list of the requirements for licensing or the services that can be offered under each regime. For more detailed information about the licensing regimes and the services that can be offered under each regime, we recommend consulting the respective authorities' websites or other publicly available sources.
UAE Virtual Assets Licensing Regimes
| VARA | DIFC | ADGM | DMCC | Federal | |
|---|---|---|---|---|---|
| Regulator/Licensing Entity | Dubai Virtual Assets Regulatory Authority (VARA) | Dubai Financial Services Authority (DFSA) | Financial Services Regulatory Authority (FSRA) | Dubai Multi Commodities Centre Authority (DMCC) | Securities and Commodities Authority (SCA) / Central Bank of the United Arab Emirates (CBUAE) |
| Applicable Jurisdiction | Emirate of Dubai (aside from the DIFC) | Dubai International Financial Centre | Abu Dhabi Global Market (Al Maryah Island) | Emirate of Dubai (aside from the DIFC) | Onshore United Arab Emirates (aside from the DIFC and ADGM) |
| Is a fully operational licensing regime in place? | Yes | Yes | Yes | Yes | Yes |
| Required Physical Presence | Emirate of Dubai | DIFC | ADGM | DMCC | UAE |
| Required Corporate Structure | Must be in one of the legal forms approved by the relevant Dubai commercial licensing authorities | Must be a Body Corporate incorporated under the DIFC Companies Law | Must be a Body Corporate incorporated under the ADGM Companies Law | Must be a DMCC incorporated company or a branch of a non-DMCC company | Must be in one of the legal forms approved by the relevant UAE trade licensing authorities |
| Application Fees (USD) | $10-30K | $15-175K | $20-145K | $10K | $15-140K |
UAE Virtual Asset Services
| Services | VARA | DIFC | ADGM | DMCC | Federal |
|---|---|---|---|---|---|
| Broker-dealer services | Yes | Yes | Yes | No | Yes |
| Advisory services | Yes | Yes | Yes | No | Yes |
| Exchange/MTF services | Yes | Yes | Yes | No | Yes |
| NFTs | Yes | No | No | Yes | No |
| Custody services | Yes | Yes | Yes | No | Yes |
| Managing virtual assets | Yes | Yes | Yes | No | Yes |
| Dealing in investments as principal | Yes | Yes | Yes | Yes | Yes |
| Restrictions on Virtual Asset Tokens | Yes: No public list of accepted virtual assets, but VARA has wide discretion to restrict certain categories of virtual assets | Yes: The DFSA maintains a public list of recognized virtual assets that may be offered within DIFC | Yes: No public list of accepted virtual assets in ADGM however the FSRA approves of virtual assets on an entity-by-entity basis. Only accepted virtual assets can be offered within ADGM | No: However regulated activities related to virtual assets may only be operated within the context of the "Dealing in investments as principal" license category | Yes: SCA maintains a public list of accepted virtual assets that may be offered within the UAE |
| Can security/investment tokens be offered? | Yes | Yes | Yes | No | Yes |