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🇦🇪 VARA MVL License

VARA MVL License —
Virtual Asset Broker-Dealer UAE 2025

The VARA MVL (Market-Making and Virtual Asset Broker-Dealer) license is the primary route to operating a virtual asset brokerage in Dubai, UAE. This guide covers the full MVL license application process, requirements, capital obligations, and compliance framework.

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What is the VARA MVL License?

The VARA MVL (Virtual Asset Broker-Dealer) license authorises the holder to operate as a virtual asset broker or dealer in Dubai — facilitating the purchase, sale, and exchange of virtual assets between buyers and sellers as principal or agent.

The MVL license is distinct from the MSC (exchange) license. MVL holders act as intermediaries rather than operating a centralised order book. This makes MVL the appropriate license for OTC desks, digital asset brokerage firms, and B2B virtual asset transaction facilitators.

MVL License Requirements

✓
Legal Entity$0
UAE mainland or Dubai free zone entity required. ADGM and DIFC entities may operate under DFSA regulation.
✓
Minimum CapitalAED 2M
AED 2,000,000 (~$545,000 USD) minimum paid-up capital.
✓
Management TeamRequired
Senior management including CEO and Compliance Officer must be fit-and-proper assessed by VARA.
✓
AML/CFT ProgrammeMandatory
Comprehensive AML/CFT policies, MLRO appointment, KYC/KYB procedures, transaction monitoring system.
✓
Technology AuditRequired
Independent technology and cybersecurity audit of trading and operational systems.
✓
Business PlanRequired
Detailed 3-year business plan including financial projections, revenue model, and regulatory compliance roadmap.
✓
Professional Indemnity InsuranceRequired
PI insurance coverage appropriate to the scale of operations.

MVL Application Process

1
Pre-Application2–4 wks

Engage VARA for initial regulatory consultation. Assess licensing requirements against your business model.

2
Entity Formation2–4 wks

Incorporate UAE entity. Establish corporate structure, ownership, and governance documentation.

3
Document Preparation6–10 wks

Prepare business plan, policies and procedures, AML/CFT programme, technology audit, financial projections.

4
VARA Application Submission1 wk

Submit full application via VARA portal with all supporting documentation and application fee.

5
VARA Review8–16 wks

VARA reviews application, may request additional information or clarifications. Fit-and-proper assessments.

6
In-Principle Approval2–4 wks

VARA issues in-principle approval with conditions. Remaining requirements satisfied.

7
License Issuance1–2 wks

Full MVL license issued. Virtual asset brokerage operations may commence.

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