VARA lawyer in Dubai.

What a VARA lawyer actually does

VARA is a full prudential and conduct regulator, not a licence counter. Getting licensed and staying licensed is a programme, and our VARA practice covers all of it:

• Perimeter analysis: whether your model falls inside one of the eight regulated activities, and where the boundaries with the DIFC, ADGM and federal CMA regimes sit.
• The application itself: the Initial Disclosure Questionnaire, the full application pack, the business plan and the rounds of VARA queries that follow.
• Capital and prudential design: paid-up capital by activity, net liquid assets at 1.2 times monthly operating expenses, insurance and the trust account arrangements VARA requires.
• Governance and approved persons: two Responsible Individuals, a UAE-resident Compliance Officer with five years of compliance experience, the MLRO, and the three roles that may be outsourced (MLRO, CISO, DPO).
• AML/CFT frameworks: the Business Risk Assessment, policies aligned to the compulsory rulebooks, and goAML registration.
• Issuance and tokenisation: the VA Issuance Rulebook, Category 1 fiat-referenced and asset-referenced tokens, and real-world asset structures.
• Supervision and enforcement: VARA 2.0 supervision, rulebook change, information requests, remediation and penalty response.

The eight regulated activities, and where you fit

Proprietary trading sits outside the eight activities but is not unregulated: VARA expects a No Objection Certificate, and registration becomes mandatory at USD 250 million equivalent of virtual asset investment within any rolling 30-day period. See our proprietary trading guide.

What VARA itself charges

Under Schedule 2 of the Virtual Assets and Related Activities Regulations, VARA's application fee is AED 40,000 with AED 80,000 annual supervision for Advisory Services and for VA Transfer and Settlement Services, and AED 100,000 with AED 200,000 annual supervision for every other activity. Each additional activity adds 50 percent of the lower application fee. Paid-up capital under the Company Rulebook ranges from AED 100,000 for Advisory to AED 800,000 or 1.5 million for Exchange, depending on custody arrangements. The full picture, including the costs applicants forget to budget, is in our VARA licence cost guide; our own fees are scoped and fixed before you commit.

Why Neo Legal for VARA work

Three reasons clients choose us, each verifiable. First, regulator-side experience: our Director of Licensing and Regulatory Compliance, Manpreet Kaur, previously served inside VARA itself, so applications are built the way the regulator actually reads them. Secondly, named public work: Neo Legal advised Animoca Brands on its VARA VASP licence, announced February 2026, the first regulated VASP licence in the Animoca Brands group globally. Thirdly, published depth: we maintain 25+ public VARA guides and a live UAE licensing tracker, which is why our analysis is regularly the reference material other advisers work from. Every engagement is partner-led, and Neo Legal is the UAE practice of Cornwalls, the Australian firm established in 1891.