VARA Management & Investment Services Licence
Managing virtual asset portfolios or investment products for clients in Dubai requires VARA's VA Management and Investment Services licence. VARA expects clear client mandates, fair valuation, conflicts management and strong client asset protection. VAF Global prepares the governance and compliance documentation for crypto asset managers.
Who needs this licence?
- Discretionary crypto portfolio managers
- Managers of virtual asset investment strategies
- Wealth platforms offering managed crypto portfolios
- Firms offering structured or yield-style virtual asset products
What management and investment covers
Discretionary management
Making investment decisions in virtual assets on behalf of clients.
Investment products
Offering or managing virtual asset investment products for clients.
Mandate and reporting
Operating within agreed investment mandates and reporting to clients.
Fund structures
Some fund structures may also involve other regulators, depending on where the fund is set up.
Key requirements
- A commercial licence from Dubai Economy and Tourism (DET) or a Dubai free zone authority
- Compliance with VARA's compulsory rulebooks: Company; Compliance & Risk Management; Technology & Information; Market Conduct
- Fit and proper shareholders, board and senior management, including a Compliance Officer and MLRO
- AML/CFT programme with KYC, transaction monitoring (KYT), sanctions screening, Travel Rule and goAML reporting
- Client agreements and investment mandates
- Valuation, pricing and performance reporting policies
- Conflicts of interest and best execution policies
- Arrangements with a licensed custodian for client assets
The licensing process
- 1
Activity mapping
Confirm exactly which VARA activities your model needs. Many businesses need more than one.
- 2
Initial Disclosure Questionnaire
Submit VARA's IDQ through DET or your Dubai free zone, with the business plan and owner and management details.
- 3
Approval to Incorporate
VARA issues an Approval to Incorporate. Set up the company and operations; no virtual asset activity is allowed yet.
- 4
Full application
File the full licence application with policies, risk assessments, financials and key personnel.
- 5
VASP Licence
VARA issues the licence, which may carry operational conditions; supervision and annual renewal follow.
How VAF Global helps
We prepare and run the compliance side of your licence, so your application meets the regulator's expectations from day one.
- Activity mapping across VARA rulebooks
- AML/CFT, KYC, sanctions and Travel Rule policies
- Business-wide and customer risk assessments
- Compliance manuals aligned to the activity rulebook
- Outsourced MLRO (where VARA permits) and support for your in-house Compliance Officer
- KYT transaction monitoring with our KYT tool
VARA Management & Investment Licence: FAQ
Is a crypto fund in Dubai regulated by VARA?
+
It depends on the structure and where the fund and manager are established. Managing virtual assets for clients in Dubai typically falls under VARA, while DIFC and ADGM fund regimes apply within those centres.
Does a crypto asset manager need its own custody licence?
+
Not necessarily. Many managers use a licensed custodian instead of holding client assets themselves.
Can I combine this with other VARA activities?
+
Yes. A VARA licence lists each authorised activity, and many firms hold several. Each additional activity brings its own rulebook requirements, so it is best to plan the full scope before applying.
Other UAE licensing guides
Last reviewed October 2026. This guide is general information for compliance planning, not legal advice. Regulatory requirements change; always confirm current rules with the regulator. VAF Global is a compliance consultancy and does not provide legal services.