Find a VARA Compliance & Enforcement Lawyer

The Virtual Assets Regulatory Authority, established under Dubai Law No. 4 of 2022, is Dubai’s dedicated regulator for virtual asset activity: Article 6 of that Law makes it the competent entity in the Emirate for regulating, supervising and overseeing virtual asset services.

VARA’s jurisdiction covers Dubai, excluding the DIFC, which has its own separate regulatory framework under the DFSA, an important distinction for any business operating in the emirate.

For a licensed firm, VARA’s role is continuing supervision: Article 6 of the Law gives it the power to oversee and supervise virtual asset service providers to ensure their compliance with the Law, the resolutions issued under it and other legislation in force in the Emirate, and Part IX of VARA’s Regulations sets out its powers of examination and enforcement.

VARA’s Regulations require licensed firms to comply at all times with its rulebooks as they are amended from time to time, so the rules a firm must meet can change after it is licensed, which makes it important to work with a lawyer who has genuinely current knowledge of the applicable rules.

VARA opening an examination or investigation, or asking for books and records, is one of the clearest reasons to seek guidance: every entity must co-operate with VARA and provide the books and records it requests, and a licensed firm must produce requested information within the period set in VARA’s notice.

Receiving a written reprimand, an enforcement notice requiring non-compliance to be rectified within a specified period, or a fine is another, and how a firm responds matters: VARA’s Regulations list the entity’s conduct after the violation and throughout any investigation or examination among the factors VARA weighs when deciding whether to fine and how much.

Facing a compliance query or concern raised by VARA regarding an existing licensed business is another important reason to seek experienced legal guidance.

The prospect of a licence being limited, suspended or revoked, or of an order to cease a virtual asset activity, is a reason to seek guidance promptly, as is any VARA decision you may want to challenge through the grievance process.

VARA examinations and investigations, including requests for books and records and for information to be produced within the period VARA sets.

Ongoing VARA compliance, addressing governance, AML/CFT, and reporting obligations that come with an active licence.

Marketing and promotion compliance, ensuring virtual asset marketing activities meet VARA’s specific rules.

Regulatory queries and responses, addressing questions or concerns VARA raises during ongoing supervision.

Enforcement action and grievances, from responding to a written reprimand, an enforcement notice or a fine to submitting a written grievance against a VARA decision.

LEXNOVA is not a law firm and does not provide legal advice. Legal Connect exists to help you describe your VARA-related needs clearly, then explore potentially suitable legal professionals from our network.

We consider factors like your specific business activity, exchange, custody, brokerage, or another category, and whether your matter is ongoing compliance, a VARA examination, or enforcement action.

Every potential match involves human review before an introduction is made, VARA matters require genuinely current, specific regulatory knowledge deserving careful attention.

Once we identify potentially suitable professionals, we help facilitate an introduction, from there the lawyer can properly assess your specific business and your compliance or enforcement position.

The UAE’s approach to virtual asset regulation involves multiple regulators, each with a distinct jurisdiction, an important area to get right both legally and practically.

VARA regulates virtual asset activity specifically in Dubai, excluding the DIFC, this is often the primary framework for retail-facing exchanges and platforms in the emirate.

The CMA, the federal Capital Market Authority (the Securities and Commodities Authority, SCA, renamed under federal decree-laws in force since 1 January 2026), regulates the capital markets sector at the federal level and is not limited to securities: it also regulates virtual asset service providers, and in April 2026 it issued a Virtual Assets Framework. For virtual asset service providers, the licensing line between the two is drawn by territory: under the cooperation agreement the SCA and VARA signed in September 2024, firms operating in or from Dubai are licensed by VARA and firms operating out of the other emirates by the federal regulator, and the agreement also covers mutual supervision of these firms and the imposition of penalties and fines.

The DFSA governs the DIFC specifically, and the FSRA governs Abu Dhabi’s ADGM, meaning your specific location and business activity determine which regulator, or regulators, actually apply to you.

Under Part IX of VARA’s Virtual Assets and Related Activities Regulations 2023, every entity within VARA’s remit is subject to investigation or examination at any time VARA considers necessary, and must co-operate and provide all the books and records VARA requests.

An examination lets VARA determine a firm’s financial condition, the safety and soundness of its business, its management and operational policies, and whether it has complied with the laws, Regulations, Marketing Regulations, Rules and Directives that apply to it, and VARA may extend it to an affiliate of the firm.

Requested information or documents must be produced before the end of the period specified in VARA’s notice, unless the firm shows VARA that the period is unreasonable, and through the means the notice specifies, and VARA may require them to be verified or authenticated.

Separately, under Article 21 of Dubai Law No. 4 of 2022, VARA employees nominated by resolution of the Director General of the Dubai World Trade Centre Authority, to which VARA is affiliated, have law enforcement capacity: they may inspect virtual asset service providers, access their records and documents, and issue violation reports.

Part IX.C of VARA’s Regulations allows VARA to take enforcement action against any entity on grounds that include a violation of the law, including the Dubai VA Law and federal AML/CFT laws, or of VARA’s Regulations, Marketing Regulations, Rules or Directives.

The measures listed range from written reprimands, enforcement notices requiring non-compliance to be rectified within a specified period and cease-and-desist notifications, through limiting the scope of a licence, suspending or revoking it and requiring a public statement, to fines or other civil penalties and additional supervision, monitoring or reporting requirements, and VARA may act directly against a firm’s Responsible Individuals.

In deciding whether to fine and how much, VARA considers the full circumstances of the case, including the nature, seriousness and impact of the violation, the entity’s conduct after it and during any investigation or examination, and its compliance history; for certain first-time violations VARA may consider not issuing an immediate fine and instead require effective remedial action. A continued violation can attract periodic penalties on top of a fine.

Decisions can be challenged: under Article 22 of Dubai Law No. 4 of 2022, any affected party may submit a written grievance to the Director General of the Dubai World Trade Centre Authority, to which VARA is affiliated, within 30 days of being notified of the decision, action or measure, a committee formed for the purpose determines it within 15 days of referral, and the committee’s decision is final. VARA also publishes a list of the fines issued by its enforcement function on its website.

Holding a VARA license comes with ongoing obligations, including governance standards, AML/CFT compliance, and regular reporting requirements.

VARA also maintains specific rules around the marketing and promotion of virtual assets, relevant to how licensed businesses communicate with current and prospective clients.

Staying current with VARA’s evolving rulebook is an ongoing responsibility for licensed businesses, given how actively this regulatory framework continues to develop.

A lawyer can help ensure your business maintains appropriate compliance as both your operations and VARA’s requirements evolve over time.

Larger firms may bring more resources for complex examinations and enforcement matters, or for businesses with significant institutional backing.

Independent lawyers with genuine, current VARA experience can offer more direct, accessible support, particularly for smaller or earlier-stage virtual asset businesses.

Given how specialized this area is, and that VARA’s rulebooks are amended from time to time, prioritizing genuine, current VARA-specific experience matters more than firm size alone.

This is a preference you can share through Legal Connect, and we’ll take it into account alongside the specific expertise your situation requires.

Have they handled VARA examinations, enforcement notices or grievances for businesses with an activity similar to yours before?

How current is their knowledge of VARA’s latest rulebook updates, given that VARA’s rulebooks are amended from time to time?

What is their fee structure for responding to VARA, and does it cover ongoing compliance support as well?

These are reasonable questions any credible VARA-focused lawyer should answer clearly and confidently.

Fees vary considerably based on the complexity of your business, the scope of a VARA examination or enforcement matter, and whether you need ongoing compliance support.

LEXNOVA does not set or control fees, this is communicated directly by each professional, and it’s reasonable to request a clear, itemized estimate before proceeding.

Where VARA has opened an examination or taken enforcement action, understanding the likely scope of the legal work, and how it will be charged, matters early.

A credible lawyer should be able to give you a realistic, transparent sense of costs relative to your specific business plans.

A lawyer who conflates VARA with other UAE virtual asset regulators, or can’t clearly explain the distinction, likely lacks the current, specific expertise this area demands.

Outdated guidance that doesn’t reflect VARA’s more recent rulebook updates is a genuine risk given that VARA’s rulebooks are amended from time to time.

Overly confident guarantees about how VARA will resolve an examination or enforcement matter are worth treating with caution.

Trust your own judgment, given how technical this area is, it’s entirely reasonable to seek clear, current, and honest guidance before proceeding.