VARA Licence Checklist: Compliance Documents to Prepare Before You Apply
The compliance documents and decisions to have ready before submitting a VARA licence application, from risk assessments to Travel Rule procedures.
Most delays in a VARA application come from gaps in the compliance framework, not the business plan. Preparing these documents early makes the process faster and avoids repeated questions from the regulator.
1. Activity and business model mapping
Be precise about which VARA activities you need and why. A clear map of products, client types, jurisdictions and flows of funds and assets underpins every other document.
2. Governance and people
- Group structure and ultimate beneficial owners
- Board and senior management with fit and proper information
- Compliance Officer and MLRO appointments, in-house or outsourced
- Organisation chart, roles, responsibilities and reporting lines
3. Risk assessments
A business-wide risk assessment covering customers, products, delivery channels, geographies and technology, plus a customer risk-rating methodology that drives due diligence levels.
4. AML/CFT policies and procedures
- KYC, CDD and enhanced due diligence procedures
- Transaction monitoring and blockchain analytics (KYT)
- Sanctions screening and targeted financial sanctions procedures
- Travel Rule procedures and counterparty VASP due diligence
- Suspicious transaction reporting through goAML
- Record-keeping and training plan
5. Rulebook-aligned manuals
VARA's compulsory rulebooks (Company; Compliance & Risk Management; Technology & Information; Market Conduct) plus the rulebook for each activity set detailed expectations. Your manuals should show how each requirement is met in practice.
6. Technology and security
Information security policy, wallet and key management (where relevant), business continuity and incident response, and plans for independent technology audits.
Key takeaways
- Map activities first; everything else depends on it.
- Risk assessments drive your AML/CFT design, so do them early.
- Manuals should show how you meet each rulebook requirement in practice.
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.