Table of Contents
Frequently Asked Questions
Do transfer services need a VARA license in Dubai?
Yes. Transferring virtual assets between parties or settling virtual asset transactions commercially in or from Dubai, outside the DIFC, requires VARA approval under activity 6619.88 before Meydan Free Zone can issue the business license.
Can a settlement provider hold client assets?
Not as a custodian. Custody is activity 6619.84 and cannot be combined with transfer and settlement. Any holding of client assets beyond the settlement process itself requires a separately licensed custodian entity.
What is the travel rule and does it apply?
It requires originator and beneficiary information to accompany virtual asset transfers above defined thresholds. VARA's rulebooks apply it to licensed providers, and transfer and settlement firms sit squarely within its scope given the nature of the activity.
How is this different from the conventional settlement code?
Financial transaction processing and settlement in conventional finance is activity 6619.01 and requires Central Bank initial approval. Activity 6619.88 covers the same function for virtual assets specifically and falls under VARA's authority instead.
Can I combine settlement with exchange or brokerage?
Yes. Activity 6619.88 may be combined with advisory, broker-dealer, exchange, lending and borrowing, and management and investment. Only proprietary trading and custody are excluded, and VARA assesses each combination on its own merits.
What does VARA expect around failed settlements?
Documented exception handling, defined responsibility for failed or delayed transfers, reconciliation controls and dispute procedures, alongside resilience and continuity arrangements. The detailed requirements sit within VARA's rulebooks for licensed providers.
How to Start a Virtual Assets Transfer and Settlement Services Business with Meydan Free Zone
Every trade has to finish. Assets move from one party to another, obligations are discharged, records are updated, and someone is accountable if any of that fails. Transfer and settlement is the part of the market nobody notices until it breaks. Activity 6619.88 is the license for operating it in virtual assets from Dubai.
The volume gives the work its weight. Virtual asset transaction volumes across regulated entities in Dubai reached almost AED 2.5 trillion in 2025[1], every unit of which had to be transferred and settled. VARA had licensed fifty virtual asset service providers by July 2026, and classified thirty-nine of them as fully operational at the end of 2025[2], with the regulator noting that holding a license does not by itself mean a firm has completed its commercial launch.
Settlement infrastructure is where regulated markets are made credible. VARA was established under Dubai Law No. 4 of 2022 as the world's first dedicated virtual assets regulator[3], and it approves transfer and settlement providers before Meydan Free Zone can issue a license, because the failure modes in this activity affect every other participant in the chain.
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Trillions Settled by a Maturing Licensed Market
A Dubai-licensed settlement provider operates in a market where almost AED 2.5 trillion in regulated virtual asset transactions had to be transferred and settled during 2025, and where thirty-nine of the fifty firms holding licenses were classified by the regulator as fully operational at the end of that year.
Sources: Virtual Assets Regulatory Authority (2025), Emirates News Agency (WAM), Dubai Government Media Office
Who Is This Activity For?
6619.88 - Virtual Assets Transfer and Settlement Services
This activity sits within the broader class of other activities auxiliary to financial service activities, which covers firms supporting financial markets without taking positions in them. Activity 6619.88 is the post-trade member of the virtual asset group inside it, and it is the direct virtual asset analogue of the transaction processing and settlement work that sits under 6619.01 in conventional finance.
Under code 6619.88 you are licensed to transfer virtual assets between parties and to settle virtual asset transactions on their behalf. The boundary is that you are completing an agreed transaction rather than originating one. You do not decide what is traded, you do not match the orders, and you do not hold the assets as a custodian outside the settlement process.
Beyond this activity, Meydan Free Zone also supports related licences such as Virtual Assets Exchange Services, Virtual Assets Broker-Dealer Services, and Virtual Assets Custody Services.
A Virtual Assets Transfer and Settlement Services license typically covers:
- Transfer of virtual assets between parties on client instruction
- Settlement of virtual asset transactions and discharge of the resulting obligations
- Reconciliation of transfers against trade records and counterparty confirmations
- Netting and batching of obligations where the settlement model provides for it
- Transaction traceability, record keeping and travel rule compliance
- Failed settlement handling, exception management and dispute resolution
- Operation of settlement infrastructure, including resilience and continuity arrangements
Service Scope
Post-Trade Settlement
Completing the transfer leg once a trade has been agreed elsewhere. The provider reconciles what each side owes, moves the assets and evidences finality. Clients are exchanges, brokers and institutional desks, and the service is judged on how it behaves when something goes wrong rather than when everything works.
Transfer and Payment Services
Moving virtual assets between parties on instruction, whether for commercial payment, cross-border movement or treasury transfer. The technical operation is straightforward; the regulated obligations around traceability, originator and beneficiary information and sanctions screening are where the work actually sits.
Settlement Infrastructure Provision
Operating the rails rather than the individual transfers: the systems, connectivity and processing capacity that other licensed firms settle across. Resilience is the entire proposition, because an outage here becomes failed settlement for every firm connected to it.
WHAT THIS ACTIVITY EXCLUDES
It is important to note what activity 6619.88 does not cover. Safekeeping client assets on an ongoing basis is 6619.84, Virtual Assets Custody Services, which cannot be combined with transfer and settlement, so any holding beyond the settlement process itself requires a separately licensed custodian. Matching orders between participants is 6619.85, Virtual Assets Exchange Services. Executing orders on client instruction is 6619.83. Advising clients is 6619.82, and discretionary management is 6619.87. Lending and borrowing products are 6619.86. Trading on your own account is 6619.81 and cannot be combined with anything. Financial transaction processing and settlement in conventional finance, including card transactions, sits under 6619.01 and requires Central Bank initial approval rather than VARA approval.
In short: if you are completing the transaction, you are in. If you are deciding it, matching it, or holding the assets afterwards, you are not.
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Licensing & Compliance
Third-Party Approval:
You need approval from the Virtual Assets Regulatory Authority (VARA) before your business license is issued. This activity cannot be combined with Virtual Assets Proprietary Trading in Crypto-commodities or Virtual Assets Custody Services.
Anti-Money Laundering Compliance:
This business activity is exempt from AML compliance requirement.
References
[1] AGBI, Tokenisation fuels Dubai's virtual asset growth, says regulator, citing Dubai Government Media Office, July 2026. agbi.com
[2] GN Crypto, VARA Grants 50th VASP License to Tribe Tokenisation in Dubai, on operational status of licensed VASPs at end 2025, July 2026. gncrypto.news
[3] The Official Portal of the UAE Government, Regulation of digital properties, on Dubai Law No. 4 of 2022 and the establishment of VARA. u.ae
[4] Arabian Business, Dubai VARA reports $681bn in virtual asset volumes, reporting VARA figures for 2025, November 2025. arabianbusiness.com
[5] Virtual Assets Regulatory Authority, Licence Applications, on the two-stage licensing process and submission through a Dubai free zone authority. vara.ae
