VA Custody License
License for secure safekeeping and storage of client virtual assets using cold storage and multi-signature wallets.
VARA Regulations 2023, VA Custody Services Rulebook, Dubai Law No. 4 of 2022
Capital Required
AED 600,000-800,000 plus 1.2x monthly expenses
Timeline
5-9 months
Fees
AED 100,000 application + AED 200,000 annual supervision
Regulatory Body
Virtual Assets Regulatory Authority (VARA)
Legislative Framework
Dubai Law No. 4 of 2022, Virtual Assets and Related Activities Regulations 2023, VARA Rulebooks (13 total: 5 Compulsory, 8 Activity-Specific)
Last updated: August 2025
Key Requirements
Base capital of AED 600,000-800,000 (higher for entities holding assets over AED 100 million) plus operational expenses
Cold storage and multi-signature wallet architecture with minimum 2-of-3 or 3-of-4 signing per VARA standards
Segregated custody infrastructure as separate legal entity distinct from trading, advisory, or broker operations
Comprehensive private key management procedures with physical and digital access controls documented per VARA
Chief Information Security Officer and Chief Compliance Officer with custody technology expertise
Insurance coverage including cyber liability (minimum AED 2,000,000) and crime/fidelity (100% of assets)
Regular security audits minimum annually by independent third-party with penetration testing documented
Clear custody agreements specifying asset segregation, redemption procedures, and liability limitations
Application Process
Prepare comprehensive VA Custody license application with detailed custody technology architecture
Provide organizational structure with management CVs for CISO and Chief Compliance Officer
Submit comprehensive operational procedures including private key management and cold storage protocols
Include compliance manual covering custody standards, audit procedures, and segregation mechanisms
Provide insurance certificates and capital adequacy verification from third-party auditors
Undergo VARA security review including technical assessment of custody infrastructure and controls
Expected Total Timeline
5-9 months
Ongoing Obligations
After obtaining your VA Custody License, these are the continuing compliance requirements you must maintain.
Monthly asset reconciliation and monthly attestation from independent custodian verifying balances and segregation
Quarterly capital adequacy reports and annual independent audit of financial statements and procedures
Annual security audits including penetration testing and vulnerability assessments with results to VARA
Annual fit-and-proper assessments for CISO and Chief Compliance Officer with VARA notifications of changes
Quarterly reporting of custody client base, asset volumes under custody, and insurance coverage status
Maintain cyber liability and crime insurance continuously at specified minimums with immediate notice of lapses
Cost Summary
Capital Requirement
AED 600,000-800,000 plus 1.2x monthly expenses
Application & Licensing Fees
AED 100,000 application + AED 200,000 annual supervision
Jurisdiction Setup Cost
$50,000-$100,000
Annual: $40,000-$120,000
Other UAE / Dubai Licenses
Explore other license types available in UAE / Dubai.
VA Exchange License
VA Broker-Dealer License
VA Lending & Borrowing License
VA Management & Investment License
VA Advisory License
VA Issuance License
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