Table of Contents
Frequently Asked Questions
What separates management from advisory?
Discretion. Under activity 6619.82 you recommend and the client decides. Under activity 6619.87 you decide and act on the client's behalf. If you can trade a client portfolio without asking each time, you need the management license.
Can I hold the assets I manage?
Not under this license. Custody is activity 6619.84 and cannot be combined with management, so client assets must sit with a separately licensed custodian while you retain the discretionary mandate over how they are invested.
Can I launch a virtual asset fund from Meydan Free Zone?
Activity 6619.87 covers management of pooled virtual asset vehicles and requires VARA approval before the license is issued. Fund structuring itself may raise additional considerations, so confirm your intended vehicle with VARA during the application.
Can I combine management with advisory and brokerage?
Yes. Activity 6619.87 may be combined with advisory, broker-dealer, exchange, lending and borrowing, and transfer and settlement. Only proprietary trading and custody are excluded, and VARA reviews each combination on its own merits.
Does managing my own company's treasury need this license?
No. Managing your own capital is proprietary trading under activity 6619.81, which cannot be combined with any other activity. Activity 6619.87 applies specifically where the capital being managed belongs to clients.
What reporting does a licensed manager owe clients?
Portfolio valuation, performance measurement and periodic reporting against the agreed mandate, alongside disclosure of material changes to strategy or risk. VARA's rulebooks set the detailed frequency and content requirements for licensed managers.
How to Start a Virtual Assets Management and Investment Services Business with Meydan Free Zone
Management is what advice becomes when the client stops deciding. Under a discretionary mandate the manager chooses what to buy and sell, acts on that decision, and answers for the result. Activity 6619.87 is the license for exercising that discretion over virtual assets in Dubai.
The capital a manager needs is already in the emirate. Assets under management across VARA-regulated entities exceeded AED 9.6 billion in 2025, and more than three million investors and traders are serviced from Dubai[1]. VARA issued its fiftieth virtual asset service provider license in July 2026[2], and regulated transaction volumes reached almost AED 2.5 trillion across the year[3].
Discretionary management is held to a higher standard than advice, and reasonably so. VARA was created under Dubai Law No. 4 of 2022 as the first regulator anywhere dedicated solely to virtual assets[4], and a manager acting on client capital carries obligations around mandate, suitability, valuation and reporting that an adviser does not.
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Fifty Licensed Providers and Billions Under Management
A Dubai-licensed manager operates in a market served by fifty licensed virtual asset service providers as of July 2026, where assets under management across regulated entities exceeded AED 9.6 billion in 2025 and more than three million investors and traders are serviced from the emirate.
Sources: Emirates News Agency (WAM) (2026), Virtual Assets Regulatory Authority, Dubai Government Media Office
Who Is This Activity For?
6619.87 - Virtual Assets Management and Investment Services
This activity sits within the broader class of other activities auxiliary to financial service activities, which covers firms servicing financial markets without acting as bank or insurer. Activity 6619.87 is the discretionary member of the virtual asset group inside it.
Under code 6619.87 you are licensed to manage virtual assets and make investment decisions on a client's behalf. The distinguishing feature is discretion. An adviser recommends and the client decides; a manager decides. That single difference is what separates 6619.87 from 6619.82 and it is what carries the additional obligations.
Beyond this activity, Meydan Free Zone also supports related licences such as Virtual Assets Advisory Services, Virtual Assets Broker-Dealer Services, and Virtual Assets Custody Services.
A Virtual Assets Management and Investment Services license typically covers:
- Discretionary management of client virtual asset portfolios
- Establishment and operation of pooled virtual asset investment vehicles
- Asset allocation, selection and rebalancing decisions taken on the client's behalf
- Operation of defined investment strategies such as index, market-neutral or staking mandates
- Portfolio valuation, performance measurement and client reporting
- Mandate setting, suitability assessment and investor onboarding
- Risk management, exposure limits and mandate compliance monitoring
Service Scope
Pooled Fund Management
Operating a collective vehicle that invests in virtual assets for multiple subscribers. The manager runs a single strategy across pooled capital, which brings valuation policy, subscription and redemption mechanics, and equal treatment of investors into scope alongside the investment work itself.
Separately Managed Portfolios
Managing individual client portfolios under written discretionary mandates. Each client's assets stay separate and each mandate can differ, which shifts the operational load toward suitability, mandate monitoring and per-client reporting rather than fund administration.
Defined Strategy and Yield Mandates
Running a specified strategy on client capital, whether index tracking, market-neutral positioning or staking. Clients are buying the strategy rather than the manager's discretion over individual assets, but the activity remains discretionary management because the manager still acts on client capital.
WHAT THIS ACTIVITY EXCLUDES
It is important to note what activity 6619.87 does not cover. Recommending a course of action that the client then chooses to take is 6619.82, Virtual Assets Advisory Services, and the difference is discretion rather than subject matter. Executing orders on client instruction is 6619.83. Safekeeping client assets is 6619.84, Virtual Assets Custody Services, which cannot be combined with management, so a manager must appoint a separately licensed custodian. Operating a trading venue is 6619.85, and lending and borrowing products are 6619.86. Transfer and settlement services are 6619.88. Managing the firm's own capital is 6619.81, Virtual Assets Proprietary Trading, which cannot be combined with anything. Managing conventional investment funds sits under the separate fund management codes and falls to the Capital Market Authority.
In short: if you are making the decision with someone else's capital, you are in. If you are only recommending it, only executing it, or only holding it, 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] Arabian Business, Dubai VARA reports $681bn in virtual asset volumes, reporting VARA figures for 2025, November 2025. arabianbusiness.com
[2] Emirates News Agency (WAM), VARA issues 50th VASP licence as Dubai's regulated virtual assets market continues to grow, 2 July 2026. bignewsnetwork.com
[3] AGBI, Tokenisation fuels Dubai's virtual asset growth, says regulator, citing Dubai Government Media Office, July 2026. agbi.com
[4] 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
[5] 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
