Virtual assets,regulated with intent.
Dubai built the world's first dedicated virtual-asset regulator, and the rest of the UAE followed with regimes in the DIFC, ADGM and at the Central Bank. For exchanges, custodians, token issuers, funds and Web3 builders, the question is no longer whether to be regulated but where, in which category, and how fast. We map the perimeter, prepare the application and build the compliance architecture that regulators expect to see working on day one.
Dubai's Virtual Assets Regulatory Authority (VARA), established under Dubai Law No. 4 of 2022, licenses virtual-asset service providers across Advisory, Broker-Dealer, Custody, Exchange, Lending & Borrowing, Management & Investment, and Transfer & Settlement activities, with a separate regime for token issuance. Its Rulebooks on Company, Compliance & Risk, Technology & Information and Market Conduct set capital, governance, wallet-security, market-abuse and Travel Rule standards that examiners test in detail. Outside Dubai, the Securities and Commodities Authority licenses VASPs onshore under a coordinated arrangement with VARA, the DFSA operates its Crypto Token regime in the DIFC, the FSRA regulates virtual assets in ADGM, and the Central Bank's Payment Token Services Regulation governs dirham-backed stablecoins and payment tokens.
For international entrants the practical challenges are consistent: which regime fits the business model, how to sequence entity formation and licensing, what capital and localisation are required, how to classify tokens that do not fit neatly into any category, and how to operate lawfully during the months between application and operational approval. Reverse-solicitation is narrower than most founders assume; marketing to UAE residents without a licence is itself a regulated activity.
RPLC UAE, led by Raunak Rane, works on the full arc: regulatory perimeter analysis, licence-readiness and application packs, policy suites and compliance frameworks, token and structure design, VASP-to-bank onboarding, and India-side compliance for founders and investors, including FIU-IND registration for VDA service providers and the tax regime for virtual digital assets. Formal filings and regulated activities are undertaken through appropriately licensed collaboration partners where the rules require.
Every mandate is staffed by a founding partner and a small, dedicated team. Where formal representation before UAE courts or authorities is required, we instruct and coordinate registered Emirati advocates so that clients receive one accountable file across legal consultancy and formal representation. Cross-border work between the UAE, India and the USA is run from the same file, with local counsel engaged where applicable law requires.
Determination of whether, where and in which category a business model is regulated across VARA, SCA, DFSA, FSRA and CBUAE, including reverse-solicitation limits and marketing rules.
Initial Disclosure Questionnaires, business plans, financial projections, fit-and-proper packs for Responsible Individuals, and full policy suites mapped to the VARA Rulebooks.
Compliance & Risk, Technology & Information and Market Conduct frameworks: wallet and key-management policies, market-abuse surveillance, complaints handling and outsourcing controls.
Legal characterisation of utility, security, payment and hybrid tokens, issuance approvals, whitepaper review, and structuring of token sales and airdrops to UAE and Indian residents.
CBUAE Payment Token Services Regulation analysis, dirham-backed stablecoin issuance and distribution structures, reserve and redemption arrangements and interaction with VARA and SCA regimes.
AML/CFT programmes for VASPs, goAML registration, Travel Rule solution selection and integration, sanctions screening and suspicious-activity reporting frameworks.
Foundation and DAO structures (including ADGM DLT Foundations), developer and node agreements, custody terms, exchange listing agreements, market-maker and liquidity agreements.
FIU-IND registration for VDA service providers under PMLA, tax treatment of virtual digital assets, FEMA considerations for Indian founders and investors, and India–UAE structuring.
The work, on record.
Client names withheld under counsel duties; details rendered indicative.
Licence-readiness for a global exchange entering Dubai
Perimeter analysis, business-model review, capital planning, Responsible Individual packs and full Rulebook-mapped policy suite for a Series-B exchange seeking Exchange, Broker-Dealer and Custody licences. Filings coordinated through licensed partners.
Dirham-backed payment token distribution structure
Advised a fintech on the CBUAE Payment Token Services Regulation, structuring issuance through a licensed issuer with the client as distributor, and drafting reserve, redemption and merchant-acceptance documentation.
Token classification and foundation structure for a gaming studio
Characterised a hybrid utility-governance token across UAE, Indian and EU regimes, structured an ADGM DLT Foundation, and drafted issuance terms and developer agreements for a Dubai-headquartered studio.
FIU-IND registration and tax structuring for an Indian VDA platform
PMLA registration as a reporting entity, AML programme, TDS and VDA tax compliance design and UAE holding-structure advice for an Indian crypto platform expanding to the Gulf.
Virtual Assets & Digital Economy
Reading, between the codes.
Speak to the practice.
A discreet, no-obligation first conversation, usually within one working day. Urgent matters are triaged the same day.
