SecureVisa Group

VARA Broker-Dealer Licensing: Correcting the “No Digital Presence” Myth

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 OTC counter.

This interpretation does not align with the VARA Rulebooks.

Let’s clarify the regulatory reality accurately and responsibly.

Under the VARA Market Conduct Rulebook, Broker-Dealer Services Rulebook, and Company Rulebook, licensed Virtual Asset Service Providers (VASPs) are subject to mandatory public disclosure obligations. These disclosures must be publicly accessible, and in multiple instances, the Virtual Assets Regulatory Authority (VARA) explicitly references disclosure via the VASP’s website.

What This Means in Practice

1. Public Disclosure Is Mandatory

VARA-licensed Broker-Dealers are required to make key information publicly available, including:

• License details and authorized Virtual Asset activities
• Conflicts of interest and client protection measures
• Risk disclosures related to Virtual Assets
• Asset safeguarding frameworks and third-party arrangements

The rulebooks clearly state that these disclosures must be published on the VASP’s website or other publicly accessible means. In practice, a website is not optional—it is VARA’s primary reference point for transparency.

2. Complaints Handling Must Be Disclosed on the Website

VARA is explicit on this requirement.

Broker-Dealers must clearly disclose their complaints handling procedures on the VASP’s website in a manner that is accessible and understandable to clients. This requirement alone renders the idea of operating with “no digital presence” operationally indefensible.

3. Physical OTC or Desk-Based Models Are Not Exempt

Operating through an OTC counter, physical shop, or appointment-based desk does not remove:

• Disclosure obligations
• Transparency requirements
• Oversight of client onboarding
• Transaction handling and recordkeeping responsibilities

VARA regulates how the activity is conducted, not whether it happens online or in person.

4. Technology and Operational Transparency Is Expected

Even where no trading interface or online execution platform is offered, VARA still expects clear visibility into:

• Client onboarding processes
• KYC/KYB and AML controls
• Record retention and auditability
• Cybersecurity and data protection measures

A purely “offline” compliance posture is not consistent with VARA’s supervisory model.

Bottom Line

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 reviewable compliance footprint—and in practice, this requires a proper, 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.

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