Licensing, AML and the compliance roles a regulated business must fill.
- Adviser-led: the activity and the regulator named before a licence category is
- Frameworks written for your business, not a template with the name changed
- Each fractional appointment subject to the regulator's approval, said upfront
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Who this is for
Four regulated situations, one adviser-led answer.
The activity and the regulator come first; the documents and the people follow.
Adviser-led regulatory consulting for businesses licensed or applying to be licensed in the UAE: VARA licensing advisory from the initial disclosure questionnaire to the full application, AML/CFT framework build, enterprise-wide risk assessment, independent AML programme review and Travel Rule readiness. Alongside it, fractional senior roles — MLRO, compliance officer, information security officer, finance and marketing leadership, and independent non-executive directors — for companies that need the function before they can justify the hire. Appointments that a regulator must approve are subject to the regulator's approval of the individual.
Situation
Which regulator, and what it wants to see.
Regulatory work is a question of the activity and the authority before it is a question of documents. Start with where you are.
Applying for a VARA licence
Whether the activity is a virtual-asset service at all, and the application, frameworks and people behind it if it is.
→A framework due or overdue
The AML/CFT framework, the risk assessment and the independent review a licensee has to keep current.
→A senior role, part of the time
An MLRO, a compliance officer, a CISO or a CFO now, for a fraction of a full-time headcount.
→Independent directors for the board
Non-executive directors a regulator, an investor or your own governance charter requires.
→
Scope
What you get, and what we never do
What is included
- A scoping session that identifies the regulator, the activity and the gaps between what you have and what it expects.
- The regulatory work agreed in scope — application advisory, frameworks, risk assessments, reviews or Travel Rule readiness — delivered by the adviser responsible for it.
- Named individuals for each fractional role, with the role's responsibilities, hours and reporting line written down.
- Coordination with the regulator's process through the licensing stages, with questions answered as they arrive.
- A compliance calendar and the evidence trail a regulator will ask to see.
- Plain statements of what is subject to the regulator's approval and what is not.
What is not
- Any assertion of a licence category, a timeline or an outcome that the regulator has not published or decided.
- Legal advice, which comes from a licensed law firm under its own engagement.
- Statutory audit, which is performed by a Ministry of Economy registered auditor.
- Acting as a shield: a fractional officer reports what the rules require, including to the regulator.
What it costs
Fixed where the deliverable is defined, monthly where the role is continuous.
The regulator's fees are the regulator's; ours are in the letter.
Advisory work
Scoped and fixed where the deliverable is defined — an application, a framework, a review — and monthly where the work is continuous.
Fractional roles
A monthly fee for the days agreed, stated in the engagement letter; the appointment itself is subject to the regulator's approval of the person.
Regulator and third-party fees
Application and licence fees are the regulator's and passed through at cost, itemised.
The VelaroZone service fee
Itemised in your engagement letter, never published.
A fractional appointment is priced for the days, not for the title.
Compared
A fractional role against the ways a regulated seat is usually filled.
The regulator has to approve the person; how quickly that can happen is the real difference.
How the four answer the same four questions.
Regulator's approval
- Fractional role through Velarozone
- Sought for the named person before the engagement starts
- A full-time hire
- Sought after hiring
- A large consultancy
- For the firm's staff, if seconded
- Leaving the seat empty
- Not possible: the role must be filled
Availability
- Fractional role through Velarozone
- The days agreed, from day one
- A full-time hire
- After a search, notice and a visa
- A large consultancy
- On the project's timetable
- Leaving the seat empty
- —
Knows your file
- Fractional role through Velarozone
- Yes: the same firm holds the licence
- A full-time hire
- Learns it
- A large consultancy
- Learns it
- Leaving the seat empty
- —
Cost shape
- Fractional role through Velarozone
- A monthly fee for the days
- A full-time hire
- A salary, a visa and a desk
- A large consultancy
- A project fee
- Leaving the seat empty
- The regulator's finding
| Fractional role through Velarozone | A full-time hire | A large consultancy | Leaving the seat empty | |
|---|---|---|---|---|
| Regulator's approval | Sought for the named person before the engagement starts | Sought after hiring | For the firm's staff, if seconded | Not possible: the role must be filled |
| Availability | The days agreed, from day one | After a search, notice and a visa | On the project's timetable | — |
| Knows your file | Yes: the same firm holds the licence | Learns it | Learns it | — |
| Cost shape | A monthly fee for the days | A salary, a visa and a desk | A project fee | The regulator's finding |
Process
How the work is sequenced
Each stage has its own dependencies and we report progress against them, not against one overall date.
- 01
Scope
Activity, regulator and licence route identified; gap analysis against the regulator's expectations delivered in writing.
- 02
Build
Frameworks, risk assessment and policies written for the business; fractional roles filled and their appointments documented.
- 03
Apply or review
The application prepared and coordinated through the regulator's stages, or the independent review carried out and reported.
- 04
Operate
The framework operated, the calendar run, the evidence kept, and the fractional roles delivering month by month.
How it works
Regulatory consulting and the fractional roles are led by Velarozone's senior advisers. The activity and the regulator are named first; a licence category is never asserted that the regulator does not publish.
A fractional appointment — MLRO, compliance officer, CISO, CFO or an independent director — is subject to the regulator's approval of the person, and that is said before the engagement starts, not after.
Guides
Read before you apply
Common questions
Straight answers
- What does VARA licensing advisory cover?
- The whole sequence: the initial disclosure questionnaire, the Approval to Incorporate stage and the full licence application, together with the frameworks, risk assessment, policies and senior appointments the application has to evidence. We coordinate the process with the regulator; the decision is VARA's.
- Can a fractional MLRO be appointed for a regulated business?
- The appointment is subject to the regulator's approval of the individual, and each regulator has its own expectations of the role. We put forward a named person with the experience the role needs and state plainly what is subject to approval before the application is made.
- What is the difference between an AML framework and an enterprise-wide risk assessment?
- The risk assessment is the analysis of where money-laundering, terrorist-financing and sanctions risk arises across the business. The framework is the set of policies, procedures and controls derived from it. A regulator reads them together and expects the second to follow from the first.
- What does Travel Rule readiness involve?
- Assessing which of your virtual-asset transfers carry originator and beneficiary information obligations, how that information will be collected, transmitted and screened, and what has to change in your systems and counterparties before you can comply.
- Which regulator applies to my business?
- It follows from the activity and where the entity is established: VARA for virtual-asset activities in Dubai outside the DIFC, the ADGM FSRA and the DIFC DFSA within those free zones, and the Central Bank of the UAE for banking, payments and money services. Where it is not obvious, the scoping session settles it.
- Do you guarantee a licence?
- No. A licence is the regulator's decision. What we do is make the application, the frameworks and the people behind it credible, and tell you honestly where they are not yet.
Describe the activity and the regulator you are facing
Tell us what the business does or will do, where it is or will be licensed, and which roles or frameworks you are missing. We reply with a scope and the order we would tackle it in.
Free assessment — current figures are confirmed within your adviser-reviewed route comparison. Your details are not shared with third parties.
Know your route before you file.
Tell us how you intend to operate and we will identify the questions, structure paths and preparation steps an adviser should assess. It is a planning tool, not legal, tax, immigration or banking advice.
Sources
- Virtual Assets Regulatory Authority (VARA)
- ADGM — the Financial Services Regulatory Authority
- DIFC — the Dubai Financial Services Authority
- Central Bank of the UAE
Legal notes and scope
Velarozone provides setup and operational-readiness coordination. This page is general information, not legal, tax, immigration, or banking advice.
This page is general information about UAE business setup, not legal, tax, immigration, or banking advice. Rules, fees, permitted activities, and bank policies can change. Final eligibility depends on your facts and the applicable rules at the time of application.
Licensing decisions, licence categories and the approval of individuals for regulated roles rest with the relevant regulator. Velarozone does not assert licence categories a regulator does not publish and does not promise regulatory outcomes. Fractional appointments that require a regulator's approval are subject to that approval.