The regulatory landscape for virtual assets, payments, and digital finance spans multiple jurisdictions, each with its own perimeter, licence categories, and application standards. Getting the jurisdiction right, the structure right, and the application right the first time is the difference between a smooth authorisation and months of costly remediation.
TLP Advisors works with exchanges, custodians, broker-dealers, OTC desks, DeFi protocols, stablecoin issuers, payment platforms, tokenisation vehicles, and fund managers. We define the right regulatory pathway and execute it, with every deliverable written for a specific business, a specific licence category, and a specific reviewing officer.
Regulatory perimeter analysis for crypto-asset, virtual asset, token, blockchain, DeFi, fintech, payment, custody, exchange, broker-dealer, advisory, management, investment, transfer, settlement, lending, borrowing, staking, tokenisation, and issuance business models.
UAE regulator and jurisdiction selection memo covering VARA, CMA, CBUAE, FSRA, DFSA, ADGM, DIFC, Dubai mainland, DWTC, DMCC, IFZA, RAK, and other free-zone options.
Regulated activity mapping against UAE virtual asset, financial services, payment services, securities, commodities, derivatives, stored value, retail payment, custody, exchange, broker-dealer, fund management, advisory, and issuance frameworks.
Market-entry structuring paper covering licence perimeter, entity location, group structure, holding company, operating company, regulated entity, token issuer, treasury vehicle, foundation, outsourcing model, governance, banking, substance, tax coordination, and launch sequencing.
VASP licence application pack covering application forms, business plan, regulatory business plan, financial projections, organisational chart, governance framework, controller disclosures, UBO disclosures, fit-and-proper materials, compliance documentation, AML/CFT framework, technology architecture, custody model, outsourcing register, and regulator annexures.
Regulator-facing business plan covering activity description, customer journey, products, token flows, wallet flows, custody arrangements, settlement mechanics, target markets, governance, staffing, systems, risk controls, compliance controls, AML/CFT controls, financial projections, and operating model.
Compliance policy suite covering AML/CFT, sanctions, KYC, customer onboarding, transaction monitoring, travel rule, market conduct, custody, outsourcing, complaints handling, conflicts, whistleblowing, business continuity, cybersecurity, governance, risk management, compliance monitoring, and regulatory reporting.
Regulator interaction support covering pre-application strategy, supervisory meeting preparation, regulator Q&A responses, comment-response trackers, licensing condition responses, remediation submissions, post-approval implementation plans, and ongoing regulatory notifications.
International licensing coordination for financial supervisory authorities, including BaFin, FINMA, FCA, MAS, EU MiCA competent authorities, and other non-UAE regulators where the client’s product, investors, counterparties, or operations require cross-border analysis.
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VASP licensing, answered
Questions we work through with founders, in-house counsel, and compliance teams at the start of every licensing engagement.
Yes. Any business offering virtual asset exchange, custody, transfer, broker-dealer, or management services in the UAE requires authorisation. Operating without a licence exposes the business to enforcement action and financial penalties.
VARA regulates virtual asset activity in Dubai outside the DIFC, FSRA is the regulator for ADGM, and DFSA regulates the DIFC. Each has its own perimeter, licence categories, and capital and substance requirements.
VARA issues category-specific licences covering advisory, broker-dealer, custody, exchange, lending and borrowing, management and investment, and transfer and settlement services. Most businesses require more than one category.
It depends on how the token is used. Payment tokens intended for retail payments generally fall under the CBUAE payment token framework, while other virtual assets sit with VARA. We map the product against both perimeters before selecting a pathway.
Yes. Full foreign ownership is available across the free zones and, in most cases, on the mainland. Applicants still need to meet local substance, resident director, and office requirements.
A typical application pack includes a regulatory business plan, financial projections, organisational chart, governance framework, controller and UBO disclosures, fit-and-proper materials, and a full AML/CFT policy suite.
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