Dubai’s VARA changes, coming into effect June 2025

Dubai’s crypto regulations are changing this week. As a KYT company with compliance at the forefront of our focus, we want to ensure crypto firms are able to digest any regulatory changes, and prepare for potential new obligations, as easily as possible. Our Head of Growth, Dennis, attended the CryptoExpoDubai, where he was able to obtain first hand the importance and consequences of the new changes, introduced in Rulebook 2.0.

Here, we will explore the highlights of the changes, which are coming into effect June 19 2025. If greater detail is necessary, check our full VARA Executive Report.

What are the new obligations, and how can firms comply? 

Firms must meet a wide range of real-time compliance requirements under Rulebook 2.0. This includes: 

• Conducting AML risk assessments every three months, 

• Implementing automated KYT tools to monitor wallet activity in real time 

• Verifying sources of funds, addresses and ultimate beneficial owners 

• Complying with the FTAF Travel Rule, including accurate sender and receiver data for transfers above AED 3,500 ($1000) 

• Screening transactions and clients against global sanctions lists 

• Submitting suspicious activity reports within 48 hours 

• Maintaining auditable records for 8 years 

• Demonstrating audit-readiness with live compliance simulations 

VASPS can meet some of these obligations by integrating transaction monitoring systems, like nominis.io. Our platform offers automated wallet screening, dark web intelligence, and real time alerting, allowing start ups and growth-stage firms to comply without the complexity or cost of legacy systems. 

Who is obligated to fulfil the requirements set by VARA? Who do these changes affect? 

All VASPs - Virtual Asset Providers - operating in Dubai, must comply. Covered entities include exchanges, custodians and wallet providers, lending and broker-dealer platforms, Token or Stablecoin issuers, and staking and advisory services. This list is not exhaustive and it is always recommended to perform research, to enquire whether your entity is covered. 

What are the risks of non-compliance? 

Penalties for non-compliance with Rulebook 2.0 can be significant: 

• For operating without a license: up to AED 20 million

• AML/CTF failures: up to AED 5 million 

• Missing suspicious transaction reports: up to AED 2 million 

• Operating without a real-time monitoring system: up to AED 1 million 

• Persistent violations: Daily fines of AED 20,000 to AED 200,000 

Regulatory action can target both the firm and its leadership, including compliance officers, C-level executives and board members. 

What are the challenges? 

For many firms, especially startups, compliance poses both financial and operational challenges. Licensing fees begin at AED 100,000 per activity, with an annual supervisory fee of AED 200,000. Capital reserves, audit requirements, and advanced compliance tech all add to the overhead. As of late 2024, only 34 entities had secured a VARA license, underscoring the strict bar to entry.

High costs, complex requirements, and the need for live KYT and TFS enforcement tools make it difficult for small teams to compete: unless they use purpose-built platforms like Nominis.io that are modular, automated, and cost-effective.

When is it coming into effect?

Rulebook 2.0 becomes enforceable on June 19, 2025. Firms are expected to complete their transition by Q4 2025, when audits and inspections begin. The window to prepare is short, and delays could put licenses or reputations at risk.

Why the changes matter, and why we support them

Rulebook 2.0 signals that Dubai is raising the bar. These changes bring real-time enforcement to the forefront, align Dubai’s crypto regulations with FATF standards, and protect both the financial system and end users - their digital assets and their reputations. 

At Nominis.io, we welcome this progress. Better compliance leads to stronger ecosystems. We’re proud to support VASPs in Dubai with scalable tools that simplify the complex and help firms not only meet the standard, but raise it.

While we strive for accuracy in our content, we acknowledge that errors may occur. If you find any mistakes, please reach out to us at contact@nominis.io Your feedback is appreciated!