Table of Contents
Frequently Asked Questions
What does activity code 6619.87 permit a licensed firm to do in Dubai
Activity code 6619.87 — Virtual Assets Management and Investment Services — authorises a firm to professionally manage discretionary portfolios of digital assets, provide structured investment advice, and hold or administer virtual assets on behalf of clients.
The typical client base includes high-net-worth individuals (HNWIs), family offices, institutional investors, and decentralised autonomous organisations (DAOs) seeking regulated custodians. Products in scope include tokenised securities, utility tokens, stablecoins held as portfolio instruments, and NFT portfolios managed as alternative asset classes.
Importantly, this activity code does not authorise spot trading platforms, peer-to-peer exchange operations, or brokerage execution services. If your business model combines management with exchange or brokerage functions, those activities require separate regulatory treatment.
Which regulatory authorities oversee virtual asset management businesses in Dubai
The regulatory architecture in Dubai operates across several authorities with distinct jurisdictional boundaries. The Virtual Assets Regulatory Authority (VARA), established under Dubai Law No. 4 of 2022, is the primary regulator for all virtual asset service providers operating within the emirate, including those in most free zones. A VARA licence is required separately from and in addition to a trade licence.
At the federal level, the Securities and Commodities Authority (SCA) retains jurisdiction over virtual assets that qualify as securities under UAE law, creating a dual-layer oversight structure for firms whose portfolios include tokenised securities.
The Central Bank of the UAE becomes relevant where payment tokens or stored value instruments intersect with a firm's service offering — particularly for businesses managing stablecoin portfolios or providing payment-adjacent services.
What AML and CFT obligations apply to virtual asset service providers in the UAE
Anti-money laundering (AML) and counter-financing of terrorism (CFT) obligations are non-negotiable for virtual asset businesses in the UAE. Under UAE Federal Decree-Law No. 20 of 2018, virtual asset service providers are designated as regulated financial entities subject to mandatory compliance requirements.
In practice, this means firms must implement robust Know Your Customer (KYC) procedures, transaction monitoring systems, and suspicious activity reporting protocols as a baseline condition of operating legally.
These obligations apply regardless of which free zone or jurisdiction the firm is incorporated in, and VARA's own rulebook layers additional compliance standards on top of the federal AML framework. Firms should treat compliance infrastructure as a foundational cost of doing business, not an optional add-on.
Why is Dubai considered a commercially attractive jurisdiction for virtual asset businesses
Dubai offers one of the few jurisdictions globally where virtual asset businesses can operate under a clear, enforceable, and predictable regulatory framework. That regulatory clarity is commercially significant because it enables capital, institutional clients, and talent to engage with confidence.
The UAE ranked among the top 10 countries globally for cryptocurrency adoption according to industry analysts at Mordor Intelligence, reflecting genuine market depth. VARA's comprehensive Virtual Assets and Related Activities Regulations, published in 2023, established one of the world's most detailed VA regulatory frameworks.
The UAE's broader financial services sector contributes approximately 10% of GDP, with digital finance identified as a priority growth vertical under the country's economic vision — signalling long-term government commitment to the sector.
What is VARA and when was it established
The Virtual Assets Regulatory Authority (VARA) is Dubai's dedicated regulator for all virtual asset service providers operating within the emirate. It was established under Dubai Law No. 4 of 2022 and has since published a comprehensive rulebook governing licensed virtual asset activities.
VARA's jurisdiction extends to firms operating in most of Dubai's free zones, making it the primary licensing authority for the vast majority of virtual asset businesses seeking to establish in Dubai. Its 2023 regulations are widely regarded as among the most detailed and structured VA frameworks globally.
Any firm providing virtual asset management and investment services in Dubai must obtain a VARA licence in addition to its trade licence — the two are separate requirements and both are mandatory.
What is the difference between VARA regulation and SCA regulation for virtual assets
VARA operates at the emirate level and regulates virtual asset service providers conducting business within Dubai, covering activities such as asset management, custody, advisory, and exchange services for digital assets that are not classified as securities.
The Securities and Commodities Authority (SCA) operates at the federal level and retains jurisdiction over virtual assets that meet the legal definition of securities under UAE law. Where a firm's portfolio includes tokenised securities, SCA oversight applies alongside VARA requirements, creating a dual-layer compliance obligation.
Understanding this distinction before incorporation is essential. A firm managing a portfolio that includes both non-security digital assets and tokenised securities will need to engage with both regulators and structure its compliance programme accordingly.
What types of clients and products are typically in scope for a virtual assets management firm under code 6619.87
The typical client base for a firm licensed under activity code 6619.87 includes high-net-worth individuals (HNWIs), family offices, institutional investors, and decentralised autonomous organisations (DAOs) that require a regulated custodian or portfolio manager for their digital asset holdings.
Products in scope are broad and include:
- Tokenised securities held as portfolio instruments
- Utility tokens managed within diversified digital asset portfolios
- Stablecoins used as portfolio instruments (noting Central Bank oversight implications)
- NFT portfolios managed as alternative asset classes
The activity is specifically designed for advisory and management business models rather than transactional or execution-focused ones. Firms whose model is primarily discretionary management or structured advice are best aligned with this activity code.
What is the role of Meydan Free Zone in setting up a virtual assets management business in Dubai
Meydan Free Zone is identified as a low-friction incorporation route for virtual asset management businesses in Dubai. It offers a streamlined setup process suited to firms seeking to establish quickly under activity code 6619.87 while remaining within a jurisdiction subject to VARA oversight.
Free zone incorporation in Dubai typically provides benefits including 100% foreign ownership, simplified visa processes, and consolidated licensing procedures — all relevant to international founders and fund managers entering the UAE market.
It is important to note that a Meydan Free Zone trade licence alone is not sufficient to operate a virtual asset management business. A separate VARA licence remains mandatory, and firms must also meet all applicable AML, CFT, and regulatory compliance requirements before commencing client-facing activities.
How to Start a Virtual Assets Management Business in Dubai
Dubai is one of the few places where you can run a digital asset management firm under rules that are written down and enforced. That matters commercially. Clear rules mean money, clients and staff can back you with confidence, and the compliance work, though real, is predictable.
This guide covers the Virtual Assets Management and Investment Services license, activity code 6619.87. You will learn what it lets you do, who checks up on you, and how to set up with Meydan Free Zone.
Key Stats at a Glance
What a Virtual Assets Management License Covers
Activity code 6619.87 covers managing, holding and advising on digital asset portfolios for other people. It is not the same as running an exchange or placing trades for clients.
What you can do. Run discretionary portfolios, where clients hand you the decisions. Give structured investment advice. Hold or administer virtual assets for clients.
What you cannot do. This license does not let you run a spot trading platform, a peer to peer exchange, or a brokerage that executes client orders. Those need their own approvals.
Who your clients are. Wealthy individuals, family offices, institutional investors, and DAOs looking for a regulated firm to look after their holdings.
What you might manage. Tokenised securities. Utility tokens. Stablecoins held as part of a portfolio. NFT portfolios treated as an alternative asset class.
The line matters when you apply. If your model is advice and management, 6619.87 is the right code. Mix in exchange or broking work and you need separate approvals on top.
Who Regulates Virtual Asset Managers in Dubai
VARA came out of Dubai Law No. 4 of 2022 and has published a full rulebook since. Anyone managing virtual assets in Dubai needs a VARA license as well as a trade license. The two are separate, and both are required.
Anti-money laundering rules are not optional. UAE Federal Decree-Law No. 20 of 2018 applies to virtual asset firms in full. That means customer due diligence, transaction monitoring, and reporting through goAML.
What VARA Will Ask You For
Capital. You must show you hold enough to run the business safely.
Your people. Fit and proper checks apply to directors and senior management. You also need a qualified compliance officer in place before approval.
Client assets kept apart. Client holdings stay separate from the firm's own money.
Reports and audits. Expect regular reporting to VARA, governance paperwork, and audits at set intervals.
None of this is light touch. Budget for the compliance setup from day one, not once you are trading. And note this: a Meydan Free Zone license does not exempt you from any of it. The trade license and the VARA license run alongside each other, not one after the other.
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The Market and How You Make Money
The UAE's share of regional virtual asset trading has grown since VARA arrived. Clear rules pulled in firms that used to work out of looser places, and that has made the local market deeper.
How managers charge. Three common streams, and most firms use more than one:
- Management fees: a percentage of the money you look after.
- Performance fees: a cut when you beat your benchmark.
- Advisory retainers: a set fee for family offices and institutions who want guidance rather than handing over the decisions.
Where demand comes from. Gulf family offices that have long held property, shares and private equity now want a regulated way into digital assets. A Dubai licensed manager with VARA behind it is in a far better position to serve them than an offshore firm.
Set against Singapore and the European hubs, Dubai gives you a more direct route for management work, no personal income tax, and Gulf capital on your doorstep. Invest in Dubai has more on the emirate's standing as a financial services hub.
How to Set Up with Meydan Free Zone, Step by Step
Order matters here. Your VARA approval has to run alongside the trade license, not after it.
- Step 1, confirm your activity: Check that 6619.87 matches what you plan to offer. Work out at this stage whether your model also pulls in the SCA or the Central Bank, because that shapes the compliance framework you build.
- Step 2, reserve your name and file your papers: Meydan Free Zone handles name reservation and setup documents quickly. Make sure your company name does not suggest banking, insurance or any regulated service your license does not cover.
- Step 3, start VARA in parallel: VARA's first approval needs a business plan, your anti-money laundering policies, your named compliance officer, and proof of capital. Start this at the same time as your trade license. Do not wait for one to finish.
- Step 4, open your bank account: Banks look hard at virtual asset firms. Bring your trade license, your VARA paperwork, your anti-money laundering policy, your ownership structure, and your compliance officer's credentials. It takes longer than a standard account.
- Step 5, sort visas, space and go live: Meydan Free Zone offers flexi-desk options that meet the physical presence rule. Visas are tied to your package. Once banking is done and VARA's conditions are met, you can trade.
A few services worth knowing about: mResidency handles visas for you, your team and your family. mAccounting keeps your books clean, which helps at both bank and VARA stage. mCore, mAssist and mPlus cover the wider support once you are running.
Conclusion
Managing virtual assets in Dubai works, and it carries real credibility. The catch is timing. Firms that hit delays are nearly always the ones that treated VARA as paperwork to sort out after setting up, rather than a job to run in parallel from day one.
The rules ask a lot of you on purpose. That is also what gives a Dubai licensed manager standing with institutional clients and banks that offshore firms cannot match.
Talk to the Meydan Free Zone team to check what VARA currently needs from you and get your license moving.
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