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VARA Compliance Solutions

The Virtual Assets Regulatory Authority (VARA) is the official regulator for virtual assets in the Emirate of Dubai, providing comprehensive regulatory frameworks and clear guidance on operator responsibilities. VARA addresses global risks including money laundering (ML) and terrorist financing (TF), ensuring that Dubai's virtual asset ecosystem operates with transparency, accountability, and alignment with international compliance standards. This framework safeguards investor interests and fosters confidence in the market.

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VARA Compliance Methodology
Six-phase structured compliance approach
1. Discovery Phase

Understand business model, infrastructure and regulatory scope.

2. Proposal

Define scope, timelines, deliverables and compliance roadmap.

3. Execution Phase

Audits, penetration testing, AML/KYC and PoR reviews.

4. Remediation

Resolve identified issues and re-test for compliance.

5. Reporting

Prepare regulator-ready compliance documentation.

6. Ongoing Compliance

Continuous support and regulator engagement.

Target Audience

Entities providing the following services are required to comply with VARA regulations to operate in the Emirate of Dubai:

Wallet Custody
Digital Asset Custody and Web3 Wallets
Exchange
Cryptocurrency Exchange and Trading Application
Lending Services
Cryptocurrency Lending Platform
Virtual Asset Management & Investment
DeFi Platforms (e.g., Staking and Yield Farming)
Transfer & Settlement Services
Cryptocurrency Payment Gateway & Cross-Chain Bridge Solutions
Virtual Asset Issuance
Stablecoin and Tokenization Platform
Advisory Service
Virtual Asset Advisory and Asset Management Services
CertiK Solutions for Full Compliance
Comprehensive security and compliance services tailored to VARA requirements.
Smart Contract & L1 Chain Auditing

Requirement: Engage independent auditors to assess smart contracts and L1 chain security annually and prior to new deployments.

CertiK Solution: Expert analysis and mathematical verification of smart contracts and blockchain protocols to ensure secure operations.

Application Penetration Testing

Requirement: Perform regular security testing, vulnerability audits, and maintain preventative controls.

CertiK Solution: Comprehensive penetration testing using OWASP methodology to identify vulnerabilities and mitigate risks.

Infrastructure Penetration Testing

Requirement: Regular internal and external infrastructure audits to maintain network integrity.

CertiK Solution: Network penetration testing using PTES and NIST SP 800-115 standards to ensure secure infrastructure.

Anti-Money Laundering & Risk Management

Requirement: Implement ledger tracing software, monitor transactions, and integrate with AML/CFT policies.

CertiK Solution: SkyInsights platform provides on-chain intelligence, risk scoring, and integration for AML/CFT compliance.

Proof of Reserves Audit

Requirement: Maintain reserve assets 1:1 with client liabilities, daily reconciliations, and independent audits.

CertiK Solution: PoR audits validate reserve accuracy and provide transparent reports for VARA compliance.

Formal Verification

Requirement: Independent third-party audits must be conducted before deployment, including formal verification where applicable, to ensure the integrity of systems and applications.

CertiK Solution: Formal Verification of smart contracts and critical systems to guarantee correctness, compliance, and security.

Key Management & Custody Review

Requirement: VASPs must maintain secure cryptographic key and wallet management, including auditing key generation, storage, access, and backup, addressing single points of failure, and analyzing the security of any open-source libraries used.

CertiK Solution: Whitebox testing and source code review for key management, sensitive data protection, and open-source libraries, designed to detect and mitigate risks and vulnerabilities at the code level.

Configuration Review

Requirement: VASPs must implement tactical hardening measures to limit attacker access once a compromise is detected, including emergency access revocation, network segmentation, system isolation, pre-approved emergency change procedures, and regular testing.

CertiK Solution: Evaluates servers, endpoints, and network devices to verify secure settings and tactical hardening capabilities, identifying gaps and guiding remediation to align with VARA.

Incident Response

Requirement: VASPs must implement incident response procedures, including root cause analysis and corrective actions to prevent recurrence. Incidents affecting personal data must be reported to VARA within 24 hours.

CertiK Solution: On-chain investigation support and expert advisory to establish effective incident response and recovery procedures, ensuring timely reporting according to VARA regulations.

Threat Modeling

Requirement: VASPs must conduct a security review before deploying any new feature.

CertiK Solution: Provides threat modeling and secure coding reviews to identify potential threats, mitigate vulnerabilities, and promote secure development practices.

Security Awareness Training

Requirement: VASPs must provide regular security awareness training to all personnel on common cyber threats.

CertiK Solution: Tailored programs to educate employees on security risks and best practices, reducing human error.

Penalties For Non-Compliance

Understanding the consequences of failing to meet VARA requirements.

Immediate Cease or Suspension

Stopping virtual assets activity or other business operations temporarily or indefinitely.

License Suspension or Revocation

VARA may suspend or revoke licences or related commercial trade licences in coordination with the relevant authority.

Financial Penalties

Financial penalties may be imposed based on the nature and severity of the violation with additional penalties for repeat or unpaid fines.

Ready to Achieve VARA Compliance?

Partner with CertiK to ensure your virtual asset operations meet all regulatory requirements. Our team of experts will guide you through every step of the compliance journey.