How to Start a Virtual Assets Management Business in Dubai

Dubai has positioned itself as one of the few jurisdictions globally where virtual asset businesses can operate under a clear, enforceable regulatory framework. That clarity is commercially significant. It means capital, talent, and institutional clients can engage with confidence — and it means the compliance burden, while real, is predictable.

This guide covers what activity code 6619.87 actually permits, who regulates it, and how to set up through Meydan Free Zone with minimal friction.

What Virtual Assets Management and Investment Services Covers

Activity code 6619.87 — Virtual Assets Management and Investment Services — covers the professional management, custody, and investment advisory of digital and virtual asset portfolios on behalf of clients. This is a distinct activity from operating a crypto exchange or providing brokerage execution services.

In practical terms, a licensed firm under this code can manage discretionary portfolios of digital assets, provide structured investment advice, and hold or administer virtual assets on behalf of clients. It does not, by itself, authorise spot trading platforms or peer-to-peer exchange operations.

The typical client base includes high-net-worth individuals (HNWIs), family offices, institutional investors, and increasingly, decentralised autonomous organisations (DAOs) seeking regulated custodians. Products in scope span tokenised securities, utility tokens, stablecoins held as portfolio instruments, and NFT portfolios managed as alternative asset classes.

The distinction matters for licensing. If your business model is advisory and management rather than transactional execution, 6619.87 is the correct activity. Mixing exchange or brokerage functions requires separate regulatory treatment.

Regulatory Landscape in Dubai and the UAE

The regulatory architecture for virtual asset management in Dubai operates across several authorities, and understanding the jurisdictional boundaries is essential before incorporation.

The Virtual Assets Regulatory Authority (VARA) is the primary Dubai regulator for all virtual asset service providers operating within the emirate, including those in most free zones. VARA was established under Dubai Law No. 4 of 2022 and has since published a comprehensive rulebook governing licensed activities. Any firm providing VA management and investment services in Dubai must obtain a VARA licence, separate from and in addition to its trade licence.

At the federal level, the Securities and Commodities Authority (SCA) retains jurisdiction over virtual assets that meet the definition of securities under UAE law. Where your portfolio includes tokenised securities, SCA oversight applies alongside VARA requirements.

The Central Bank of the UAE has jurisdiction where payment tokens or stored value instruments intersect with your service offering. This is particularly relevant for firms managing stablecoin portfolios or providing payment-adjacent services.

AML and CFT obligations are non-negotiable. Under UAE Federal Decree-Law No. 20 of 2018, virtual asset service providers are designated non-financial businesses and professions (DNFBPs), subject to full AML/CFT compliance requirements, including customer due diligence, transaction monitoring, and goAML reporting.

VARA Licence Categories Relevant to This Activity

VARA's rulebook includes a specific licence category for VA Management and Investment Services. Applicants must demonstrate minimum capital adequacy, satisfy fit-and-proper criteria for directors and senior management, and appoint a qualified compliance officer before approval is granted.

Ongoing obligations include custody segregation requirements, regular reporting to VARA, governance documentation, and periodic audits. These are not light-touch requirements — firms should budget for compliance infrastructure from day one, not as an afterthought.

Free zone licensing through Meydan does not exempt a firm from VARA requirements. The trade licence and the VARA licence are parallel processes that must be coordinated, not sequential.

Market Opportunity and Business Model

The UAE's share of regional virtual asset transaction volume has grown materially since VARA's establishment, driven by regulatory certainty attracting firms that previously operated from less structured jurisdictions. That migration of institutional-grade operators has deepened the local market.

Revenue models for VA management firms typically combine management fees (a percentage of assets under management), performance fees tied to benchmark outperformance, and advisory retainers for family offices or institutional clients requiring structured guidance rather than discretionary management.

Demand is being driven by regional HNWI wealth diversification. Gulf-based family offices that have historically allocated to real estate, equities, and private equity are increasingly seeking regulated exposure to digital assets. A Dubai-licensed VA manager with VARA credentials is better positioned to serve that demand than an offshore entity.

Compared to Singapore and European hubs, Dubai offers a more direct regulatory pathway for management-focused activities, combined with zero personal income tax and proximity to Gulf capital pools. The Invest in Dubai platform provides further context on the emirate's positioning as a financial services hub.

Setting Up via Meydan Free Zone: Step-by-Step

The setup process for a virtual assets management firm through Meydan Free Zone requires careful sequencing. VARA pre-approval must be coordinated alongside — not after — the trade licence process.

Step 1: Select your activity and confirm regulatory requirements. Confirm that activity 6619.87 aligns with your intended services. At this stage, identify whether your model also triggers SCA or Central Bank oversight, as this affects the compliance framework you need to build.

Step 2: Reserve your trade name and submit incorporation documents. Meydan Free Zone processes name reservations and incorporation documentation efficiently. Ensure your company name does not imply banking, insurance, or regulated financial services beyond what your licence covers.

Step 3: Initiate VARA initial approval in parallel. VARA's initial approval process requires submission of a business plan, AML/CFT policy framework, compliance officer appointment, and evidence of capital adequacy. This runs concurrently with the Meydan trade licence process — do not wait for one before starting the other.

Step 4: Open a corporate bank account. UAE banks apply enhanced due diligence to virtual asset businesses. You will need your trade licence, VARA approval documentation, AML policy, beneficial ownership structure, and compliance officer credentials. Expect the process to take longer than a standard business account opening.

Step 5: Visa allocation, office requirements, and go-live. Meydan Free Zone offers flexi-desk options that satisfy physical presence requirements for free zone entities. Visa allocations are tied to your licence package. Once banking is in place and VARA conditions are met, the business is operational.

Conclusion

Virtual assets management in Dubai is viable, regulated, and commercially credible — but it requires sequencing the VARA approval process correctly alongside the free zone licence, not after it. The firms that run into delays are almost always those that treat VARA as a post-incorporation formality rather than a parallel workstream from day one.

The regulatory framework is demanding by design. It is also what gives a Dubai-licensed VA manager credibility with institutional clients and banking counterparties that offshore structures simply cannot match.

Speak to the Meydan Free Zone team to confirm current VARA coordination requirements and get your licence process started.

References

• Mordor Intelligence (mordorintelligence.com)
• Securities and Commodities Authority (SCA) (sca.gov.ae)
• Central Bank of the UAE (centralbank.ae)
• Invest in Dubai (investindubai.gov.ae)