VARA Mining and Trading License
Client
Large-scale cryptocurrency mining and trading company


Challenge
A large-scale cryptocurrency operator was preparing to launch a UAE-based venture combining industrial cryptocurrency mining and proprietary crypto trading for a digital asset investment portfolio. The regulatory landscape was uncharted: UAE Central Bank rules, federal and emirate-level AML/CFT frameworks, crypto tax treatment, and the Dubai Virtual Assets Regulatory Authority (VARA) licensing regime all applied at once. No publicly known VARA approval for mining had been granted in Dubai before. The client needed a clear legal framework, the right entity structure, regulatory approvals, and international banking arrangements — all aligned before committing significant capital to a first-of-its-kind operation.
Solution
We provided end-to-end regulatory and structuring support to move the client from concept to a licensed UAE operation:
- Regulatory analysis — conducted a structured review of UAE Central Bank rules, federal and emirate-level AML/CFT frameworks, tax requirements for crypto income, and the VARA licensing regime, which has issued full licenses to only 21 companies since inception.
- Entity and jurisdiction design — selected the appropriate legal entity structure and UAE jurisdiction for the combined mining and trading mandate, balancing operational reality against compliance expectations.
- VARA compliance roadmap — designed a tailored pathway to regulatory approval covering policies, controls, and submissions aligned with VARA requirements for both activities.
- Incorporation and banking — supported incorporation, aligned operations with tax and compliance expectations, and initiated international banking arrangements to enable global crypto-fiat flows.
Result
The client received formal VARA approval to conduct both mining and trading — a first-of-its-kind mining approval in Dubai. Project value: USD 5.8M.
The roadmap continues under our ongoing legal guidance — shaping novel regulatory territory in one of the world's most forward-looking crypto jurisdictions.
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