VARA Proprietary Trading: NOC and Registration for Crypto Prop Traders
VARA does not currently require a licence for genuine proprietary trading of a firm's own funds in Dubai. Proprietary trading companies need a VARA No Objection Certificate (NOC), usually applied for through their commercial licensor, and must register with VARA before, or within three working days of, investing USD 250 million or more of their own virtual assets in any rolling 30-day period. Registration is not a licence. Prop traders cannot take client money or provide services to others; doing so needs a full VARA licence. VAF Global helps proprietary trading firms set up correctly and stay on the right side of the line.
Who needs this licence?
- Crypto proprietary trading firms trading their own capital
- Family offices and treasury companies investing in virtual assets
- Arbitrage and treasury desks trading only house funds, without quoting to or dealing at the request of third parties
- DMCC and other Dubai free zone companies holding a prop trading activity
How VARA treats proprietary trading
VARA NOC
Proprietary trading proceeds under a VARA No Objection Certificate, usually applied for through your commercial licensor, such as DET or your free zone authority.
USD 250m registration threshold
Registration with VARA is mandatory before, or within three working days of, investing USD 250 million or more (equivalent) of your own virtual assets in any rolling 30-calendar-day period.
Own funds only
Proprietary traders cannot accept third-party assets or provide services to clients.
When you need a full licence
Trading for clients, holding client assets or offering any VA service moves you into licensed activities such as Broker-Dealer or Management & Investment.
Key requirements
- A Dubai commercial licence (DET) or free zone licence with the appropriate trading activity
- A VARA NOC, usually applied for through your commercial licensor
- Monitoring of investment volume against the USD 250 million rolling 30-day threshold, with VARA registration before or within three working days of reaching it
- Clear evidence that only the firm's own funds are used, with no client or third-party assets
- AML/CFT controls proportionate to the business: source of funds, counterparty due diligence, sanctions screening and KYT on wallets
- No marketing that suggests you provide virtual asset services to others
The licensing process
- 1
Confirm you are truly proprietary
Check that no client money, investors' funds or third-party services are involved.
- 2
Set up the company
Obtain a DET or Dubai free zone licence (for example DMCC) with a suitable trading activity.
- 3
Request the VARA NOC
Apply for the VARA No Objection Certificate, usually through your commercial licensor.
- 4
Track the threshold
Monitor rolling 30-day volume and register with VARA before, or within three working days of, reaching USD 250 million.
- 5
Maintain controls
Keep AML/CFT, sanctions and wallet screening in place as you trade.
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.
- Assessment of whether your model is truly proprietary
- NOC and registration readiness documentation
- Volume threshold monitoring procedures
- Source-of-funds and AML/CFT controls
- Wallet and counterparty screening with our KYT tool
- Upgrade path to a full VARA licence if you take clients
VARA Proprietary Trading (NOC): FAQ
Do I need a VARA licence for crypto proprietary trading in Dubai?
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VARA does not currently require a licence for genuine proprietary trading with your own funds, but it requires a VARA No Objection Certificate, and registration with VARA is mandatory before, or within three working days of, investing USD 250 million or more in any rolling 30-day period.
What is the USD 250 million threshold?
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A firm 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 does not authorise any VA activity for others.
Can a prop trading company manage money for friends or investors?
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No. Accepting third-party assets or trading on behalf of others is outside proprietary trading and requires a VARA licence, such as Broker-Dealer or Management & Investment Services.
Can I set up a crypto prop trading company in DMCC?
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Yes. DMCC issues the company licence, and because DMCC is in Dubai, the VARA NOC and registration rules for proprietary trading apply.
Related insights
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.
Read articleKYT Explained: Crypto Transaction Monitoring for UAE Businesses
Know Your Transaction (KYT) explained: what it is, why UAE regulators expect it and how to screen wallets and transactions for risk.
Read articleOther 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.