02Your obligation here
Four authorities supervise virtual assets in the UAE; which one you answer to depends on where you sit. Whichever regime you fall under, the examiner tests the same programme behind the licence:
- A named, fit-and-proper compliance officer.
- A written AML/CFT programme.
- A documented risk assessment.
- Risk-based CDD.
- Transaction monitoring.
- Sanctions screening.
- Suspicious-transaction reporting to the UAE FIU through goAML.
Dubai mainland
VARA The Virtual Assets Regulatory Authority licenses and supervises VASPs (outside DIFC). Public register: vara.ae/en/licenses-and-register/public-register
Abu Dhabi (ADGM)
ADGM FSRA The Financial Services Regulatory Authority authorises virtual-asset activity in the ADGM free zone. Register: adgm.com/public-registers/fsra
Dubai (DIFC)
DIFC DFSA The Dubai Financial Services Authority runs the DIFC crypto-token regime. Register: dfsa.ae/public-register/firms
Federal securities
CMA The Capital Market Authority (formerly SCA) sits over the wider capital-market side. Site: uaecma.gov.ae
Any specific VARA, ADGM FSRA or DIFC DFSA rulebook threshold, capital requirement, filing deadline or transition date is confirmed against that regulator's own rulebook before it is stated. The sentence stays generic if unconfirmed.
03What we build in UAE crypto
01Licensing & new-regime buildThe AML/CFT programme VARA, ADGM FSRA or DIFC DFSA expects behind a VASP authorisation: risk assessment, policies, the compliance and MLRO function, wallet and counterparty controls, the file that survives the review.Detail →
02RemediationAfter a regulator finding, a deficiency notice or a failed audit: gap analysis against the applicable rulebook, a fix that closes the finding, and the evidence trail to prove closure at re-inspection.Detail →
03Outsourced & bridge MLRO + FIUA senior compliance officer or bridge MLRO while you recruit, plus a managed FIU: alert triage, investigations, and STR reporting to the UAE FIU via goAML.Detail →
04Independent AML auditThe independent review of your virtual-asset programme that the regulator and your board expect, tested against the current framework, with findings you can act on.Detail →
05Sanctions & integrity DDSanctions and screening controls, counterparty due diligence, and the crypto Travel Rule for originator and beneficiary information on transfers.Detail →
04Why it is urgent now
Standing exposure
Virtual assets in the UAE are already fully supervised. VARA, ADGM FSRA and DIFC DFSA license the activity today, and each maintains a public register, so an operator without a defensible AML/CFT programme is exposed at the next inspection, not at some future deadline. The pressure is standing, not seasonal.
Tell us what you are trying to license, fix or run in UAE crypto.
Fixed scope. No hourly billing. A costed plan within 48 hours.