Crypto Proprietary Trading in Dubai: VARA NOC and the USD 250m Threshold
Trading crypto with your own money in Dubai or DMCC? How VARA treats proprietary trading, when registration is mandatory and when you need a full licence.
Many founders, family offices and trading desks want a Dubai company that simply trades crypto with its own capital. VARA does not treat this as a licensed activity, but that does not mean it is unregulated. Here is how it works.
Proprietary trading is not currently licensed
VARA's licensed activities all involve serving others: advising, dealing for clients, holding client assets, running an exchange and so on. Trading purely for your own account is different. VARA does not currently require a licence for genuine proprietary trading. Instead, proprietary traders operate under a VARA No Objection Certificate (NOC), usually applied for through the commercial licensor, such as Dubai Economy and Tourism (DET) or a free zone like DMCC.
The USD 250 million registration threshold
A proprietary trader that invests USD 250 million or more (equivalent) of its own virtual assets in any rolling 30-calendar-day period must register with VARA before investing that volume, or within three working days of doing so. Registration is not a licence. Firms should track their volume continuously rather than checking once a month, because the threshold is rolling.
Where the line is
The proprietary route only works if it is genuinely proprietary. The following would usually push a business into licensed territory:
- Accepting money or assets from investors, friends or clients
- Trading on behalf of anyone else, even informally
- Offering any service to third parties, such as OTC quotes or custody
- Making a market or dealing with counterparties at their request, even with your own funds
- Marketing the company as a crypto service provider
Compliance still matters
Even without a full licence, a prop trading firm should be able to show where its funds come from, who its counterparties are and that it is not exposed to sanctioned or illicit wallets. Banks and exchanges will ask. Source-of-funds records, counterparty due diligence, sanctions screening and wallet screening (KYT) are all sensible controls.
Key takeaways
- Genuine proprietary trading in Dubai currently runs under a VARA NOC, not a licence.
- Registration is mandatory before, or within three working days of, investing USD 250 million in any rolling 30-day period.
- Any client money or third-party service requires a full VARA licence.
Related licence guides
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This article is general information, not legal advice. Regulatory requirements change; confirm current rules with the relevant regulator.