CeFi Compliance System for Crypto Wallet Holding

A crypto wallet holding operating in the UAE and Kyrgyzstan was building out its CeFi infrastructure and preparing for a Virtual Asset Regulatory Authority (VARA) license in the UAE. The structure spanned a UAE parent and a Kyrgyzstan-based operating entity, each with its own regulatory expectations. The client needed a scalable, risk-based compliance system that would satisfy current rules across both jurisdictions, anticipate forthcoming requirements, and reflect institutional-grade CeFi standards not yet codified in local law — all before scaling operations in one of the world's most demanding crypto regulatory environments.

We embedded a dedicated legal team and built a cross-jurisdictional compliance framework from the ground up.

1. Process mapping — embedded legal counsel alongside the client's internal staff to map current operations, dependencies, and limitations tied to external service providers.
2. Multi-jurisdictional regulatory analysis — covered conditions for operating in both jurisdictions, VARA licensing requirements in the UAE, and global CeFi standards expected of institutional-grade operators.
3. Gap analysis — mapped applicable regulation against current setup, identified key vulnerabilities, and built a resolution plan to close them.
4. Policy drafting — prepared a Risk Appetite Declaration and core internal policies and procedures: KYC/AML, transaction monitoring, vendor management, and data security, aligned with international financial compliance norms.