22 June 2023 – The Dubai Virtual Assets Regulatory Authority [VARA] announced earlier today a schedule of fees covering the issuance of no-objection certificates to proprietary traders, amendments or withdrawal of licence applications, and the submission of whitepapers for VARA review.
Proprietary Traders1
All proprietary traders will require a no-objection certificate to carry out the activity of proprietary trading in or from the Emirate of Dubai. VARA shall confirm its evaluation of a firm’s activity through the firm’s commercial licensor and firms assessed as carrying out the activity of proprietary trading will be required to pay an annual NOC fee of AED 1,000. For the avoidance of doubt, there is no additional fee payable in relation to the requirement for mandatory registration applicable to large proprietary traders (under Regulation IV.A.7).
Amendments or Withdrawal of Licence
- Licensed firms wishing to amend details of their VARA licence will be charged a licence update fee of AED 500 per request.
- Licensed firms seeking to withdraw from Dubai and wind down their Virtual Asset operations will be charged a licence withdrawal fee of AED 10,000.
Whitepaper Review
- Issuers of Virtual Assets seeking VARA review under VARA’s Virtual Asset Issuance Rulebook will have to pay a whitepaper submission fee of AED 5,000. Firms will then be notified of the subsequent fee (of up to AED 50,000) to be charged for completion of a detailed review. The maximum amount payable for submission and review is therefore AED 55,000.
- Submission of amendments to whitepapers (and the detailed review of such amendments) will also be subject to fees of AED 5,000 (for submission) and a further fee for completing a detailed review (of up to AED 50,000). The maximum amount payable for submission and review of an amendment is therefore AED 55,000.
Legal Review of Licensing Perimeter
Where legal opinions or memorandums are submitted to VARA for review and consideration of the regulatory perimeter applicable to a firm’s virtual asset activity, a legal review fee of up to AED 4,000 may be charged for a written confirmation to be provided by VARA.
1An Entity that actively invests in its own portfolio. See Part IV.A.7 of the Virtual Assets and Related Activities Regulations 2023. See also Part VII.A.3 of the Market Conduct Rulebook for certain (non-exhaustive) factors considered by VARA in determining whether an Entity is carrying out proprietary trading.