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.

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.

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.

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.

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.

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.

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.