A recurring misconception in the market suggests that a VARA Broker-Dealer license can be obtained without a meaningful digital presence, relying solely on a physical desk, shop, or over-the-counter counter.
This interpretation does not align with the VARA Rulebooks.
For firms seeking to operate as licensed Virtual Asset Service Providers in Dubai, it is important to understand VARA’s position accurately and responsibly. A physical presence alone is not enough to satisfy the transparency, disclosure, and operational expectations placed on licensed entities.
Under the VARA Market Conduct Rulebook, Broker-Dealer Services Rulebook, and Company Rulebook, licensed Virtual Asset Service Providers are subject to mandatory public disclosure obligations.
These disclosures must be publicly accessible. In multiple instances, the Virtual Assets Regulatory Authority refers specifically to disclosure through the VASP’s website.
This means that while VARA may allow some flexibility in how information is made available, the regulatory expectation is clear: licensed entities must maintain a publicly reviewable compliance footprint.
VARA-licensed Broker-Dealers are required to make key information publicly available to clients, regulators, and other relevant stakeholders.
This includes license details, authorized Virtual Asset activities, conflicts of interest, client protection measures, risk disclosures relating to Virtual Assets, asset safeguarding arrangements, and third-party service provider relationships.
The rulebooks state that these disclosures must be published on the VASP’s website or through other publicly accessible means. In practice, a website is not optional. It is VARA’s primary reference point for transparency and public accountability.
VARA is especially clear when it comes to complaints handling.
Broker-Dealers must clearly disclose their complaints handling procedures on the VASP’s website in a way that is accessible and understandable to clients.
This requirement alone makes the idea of operating with “no digital presence” operationally indefensible. A licensed Broker-Dealer must provide clients with clear, accessible information on how complaints are received, handled, escalated, and resolved.
A physical counter cannot replace this public disclosure obligation.
Some firms assume that operating through an OTC counter, physical shop, or appointment-based desk reduces the need for a digital compliance presence.
That assumption is incorrect.
VARA regulates the activity itself, not merely the channel through which the activity is conducted. Whether a transaction happens online, in person, or through a relationship-managed OTC process, the firm remains subject to disclosure obligations, transparency requirements, client onboarding controls, transaction handling responsibilities, and recordkeeping standards.
A desk-based model may affect the operational design of the business, but it does not remove the need for regulatory transparency.
Even where a Broker-Dealer does not offer an online trading interface or digital execution platform, VARA still expects clear visibility into the firm’s operating model.
This includes client onboarding processes, KYC and KYB controls, AML procedures, record retention, auditability, cybersecurity measures, and data protection practices.
A purely offline compliance posture is not consistent with VARA’s supervisory model. Licensed Virtual Asset businesses must be able to demonstrate that their operations are controlled, documented, reviewable, and transparent.
VARA does not license opaque businesses.
While the rulebooks allow some flexibility in how disclosures are made, they clearly establish that a licensed Broker-Dealer must maintain a publicly accessible compliance footprint. In practice, this requires a proper and functional digital presence.
A physical desk or shop alone is not a compliance strategy. It is a misunderstanding of how VARA regulates Virtual Asset activities in Dubai.
For Broker-Dealers, OTC operators, and Virtual Asset businesses seeking VARA licensing, the message is simple: regulatory transparency must be built into the business model from day one.
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