VARA Regulatory
Supervision Services
Monthly retainer for licensed Virtual Asset Service Providers. Continuous compliance, reporting management, TGRAF advisory, and incident response — designed to mirror VARA's 12-month supervision cycle.
The compliance risk
is clear and present.
VARA Regulations 2.0 represents a material escalation in supervisory intensity for all licensed VASPs operating in or from Dubai. Non-compliance carries serious consequences including unannounced investigations, enforcement inspections, sanctions, licence suspension, and cancellation.
VASPs that treat VARA supervision as a periodic exercise rather than a continuous programme face escalating regulatory exposure. The question is not whether VARA will scrutinise your operations — it is whether you will be prepared when they do.
VARA operates a rolling 12-month supervision cycle per VASP, incorporating risk monitoring, periodic reporting assessment, thematic reviews, and a 60-day VASP Annual Review window. Continuous compliance readiness is mandatory.
VASPs must submit reports prior to occurrence, upon occurrence, weekly, monthly, quarterly, bi-annual, and annually. Failure to submit accurate, timely reports is a direct trigger for unannounced investigation.
All VASPs must implement a Technology Governance and Risk Assessment Framework covering Organisational, Technical, Detection and Response, Customer VAs, and Digital Operational Resilience categories.
Each licence carries paid-up capital thresholds, NLA maintenance obligations (NLA ≥ 1.2x OPEX), bi-annual audited Proof of Reserves, and mandatory insurance coverage.
Three retainer tiers.
One specialist team.
- Monthly compliance health-check
- Reporting calendar management
- Monthly regulatory update brief
- Up to 5 hours legal advisory
- Incident response hotline
- Secure client portal access
Best for: Advisory or Broker-Dealer VASPs with limited product scope
- All Foundation services
- VARA report review & sign-off
- TGRAF gap analysis (annual)
- Prudential / NLA monitoring
- Client classification review
- Up to 12 hours legal advisory
- Wind Down Plan review (annual)
- Priority incident response
Best for: Exchange, Custody, Transfer-Settlement or Lending-Borrowing VASPs
- All Standard services
- Full report preparation & submission
- VARA assessment representation
- TGRAF implementation support
- Unlimited legal advisory hours
- Insolvency remoteness structuring
- Regulatory Sponsor programme advice
- Dedicated relationship partner
Best for: Multi-licence VASPs, large exchanges, VA issuers, or regulated sponsors
from day one.
Begin your VARA
compliance retainer.
Contact Neo Legal to schedule your complimentary compliance baseline assessment. [email protected] · +971585786357
Schedule Baseline AssessmentAnswers to the questions
clients actually ask.
The questions below are answered by Neo Legal practitioners. For tailored advice on your specific matter, please contact us directly.
What ongoing compliance obligations does a VARA-licensed VASP have?
Licensed VASPs must comply with continuous obligations across six Rulebooks: Company, Compliance and Risk Management, Market Conduct, Technology and Information, and their activity-specific Rulebook. Core ongoing requirements include monthly, quarterly, and annual regulatory reporting; AML/CFT programme maintenance; client asset segregation; technology and cybersecurity standards; marketing compliance; and annual Fit and Proper assessments for all Board members and senior management.
What reports does a VASP need to submit to VARA on a monthly basis?
Monthly reporting obligations typically include submission of financial statements (balance sheets, profit and loss, cash flow) along with VA wallet address confirmations. Any significant changes to the business — including ownership, governance, or operational matters — must be notified to VARA in writing immediately rather than waiting for a scheduled reporting cycle. Prudential Returns and Compliance Attestations must also be submitted within the prescribed timeframes.
What happens if a VASP misses a VARA reporting deadline?
Missing or submitting inaccurate reports to VARA constitutes a regulatory breach. VARA's enforcement powers include private or public reprimands, binding remedial directives, imposition of licence conditions, and in serious cases suspension or revocation of the licence. VARA adopts a risk-based enforcement approach but treats failure to self-report breaches as an aggravating factor in any enforcement assessment.
What is Net Liquid Asset (NLA) monitoring and why is it a compliance priority?
Each VARA licence category carries a minimum Net Liquid Asset threshold that the VASP must maintain on an ongoing basis — not just at the time of licence application. VASPs must proactively monitor their NLA position and report to VARA when the threshold is approached or breached. Failure to maintain NLA or to report proactively creates material regulatory exposure. The specific thresholds vary by licence category and are set out in Part VI of the Company Rulebook.
How often does VARA conduct supervision assessments of licensed firms?
VARA operates a rolling 12-month supervision cycle per VASP, during which all mandatory submissions, assessments, and reviews must be completed. The cycle includes monthly reporting, quarterly prudential reporting, and annual assessments including TGRAF review, Wind Down Plan review, and Fit and Proper confirmations for all key personnel. VARA may also conduct supervisory engagement meetings, data requests, and inspections at any point during the cycle.
What is a Wind Down Plan and does every VASP need one?
Yes. VARA requires all licensed VASPs to maintain a current, tested Wind Down Plan that demonstrates how the firm would protect client assets and cease operations in an orderly manner if required. The plan must be reviewed and updated annually, and VARA requires confirmation that the plan is operable on short notice. A Wind Down Plan that exists only on paper without genuine operational testing will not satisfy the requirement.
Do VARA's Marketing Regulations apply to VASPs that are already licensed?
Yes. The Marketing Regulations 2024 apply to all VASPs — licensed or not — and impose strict requirements on all promotional content targeting Dubai. Licensed VASPs must ensure all advertising and promotional materials are fair, clear, and not misleading, obtain VARA approval for certain content categories, and retain records of all marketing materials for a minimum of eight years. Non-compliance with the Marketing Regulations is treated as a standalone breach, separate from any licence condition violation.