VARA licensing, AML controls and the compliance roles a regulated firm 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.
Velarozone provides adviser-led regulatory consulting and fractional senior roles (MLRO, compliance officer, information security officer, finance and marketing leadership, independent non-executive directors) to businesses licensed or applying in the UAE. For VARA, the work runs from the Initial Disclosure Questionnaire, filed with Dubai Economy and Tourism or a Dubai free zone, through the Approval to Incorporate to the full VASP licence. VARA requires an MLRO with at least two years of AML/CFT experience who is a Fit and Proper Person, and any appointment a regulator must approve stays subject to that regulator's decision on the individual.
Situation
Which regulator, and what it wants to see.
VARA covers virtual-asset activity in Dubai outside the DIFC, while ADGM and the DIFC have their own regulators. Start with where the entity sits and what it does.
Applying for a VARA licence
Whether the activity falls inside VARA's perimeter, which VARA tests before it issues an Approval to Incorporate, and the application, frameworks and people behind it if it does.
→A framework due or overdue
For a VARA licensee, business and client risk assessments recur at intervals no longer than three months, and the MLRO's appointment is reviewed annually.
→A senior role, part of the time
VARA's rulebook sets a two-year AML/CFT experience minimum for the MLRO; a compliance officer, CISO or CFO may be needed before the business can carry the salary.
→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 through the licensing stages. For VARA that means the Approval to Incorporate and then the VASP licence, with answers to meetings, interviews and document requests as they arrive.
- A compliance calendar carrying recurring dates such as VARA's three-monthly risk assessments and quarterly MLRO Board reports, with the evidence trail behind each.
- 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: VARA's are set in Schedule B of the Virtual Assets and Related Activities Regulations 2023. 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, passed through at cost and itemised. For VARA, part of the licence application fee starts the review, and the rest plus the first year's supervision fee comes before the licence.
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 (for VARA, the Approval to Incorporate, then the VASP licence), or the independent review carried out and reported.
- 04
Operate
The framework operated, the calendar run and the evidence kept. For a VARA licensee that includes risk assessments at intervals no longer than three months. Fractional roles deliver 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. You submit the Initial Disclosure Questionnaire to Dubai Economy and Tourism or a Dubai free zone, with a business plan and details of beneficial owners and senior management. After the Approval to Incorporate you can set up the entity but not carry on virtual asset activities. The full licence application then needs the frameworks, risk assessment, policies and senior appointments. We coordinate the process; the decision is VARA's.
- Can a fractional MLRO be appointed for a regulated business?
- It can be, subject to the regulator's approval of the individual. VARA's rulebook requires an MLRO with at least two years of AML/CFT experience who is a Fit and Proper Person, and each regulator has its own expectations of the role. We put forward a named person 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. VARA requires the assessment outcomes to inform the policies, and repeats of the assessment at intervals no longer than three months.
- What does Travel Rule readiness involve?
- Under VARA's rulebook, before a transfer above AED 3,500 you must hold originator information (name, account number or wallet address, and residential or business address) and beneficiary information (name, and account number or wallet address). Readiness work checks how you collect, transmit and screen that data, how you handle unhosted wallets and counterparty VASPs, and what must change in your systems. VARA also expects applicants to show Travel Rule compliance during licensing.
- 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, and VARA may refuse an Approval to Incorporate or a licence where the activity falls outside its perimeter or the firm does not meet its standards. We 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 Financial Services Regulatory Authority
- DIFC Dubai Financial Services Authority
- Central Bank of the UAE: Rulebook 3.3.2 on source of funds
Legal notes and scope
Velarozone provides setup and operational-readiness coordination. This page is general information, not legal, tax, immigration, or banking advice.
General information drawn from the CBUAE Rulebook, including the Retail Payment Services and Card Schemes Regulation (C 15/2021), and Cabinet Resolution No. (134) of 2025 as published, not legal or tax advice. Rules and guidance change, so confirm the current text and each institution's own requirements before you submit.
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.