Five regulators, one token: why a private VASP tracker fills a real gap

A newly launched market tracker mapping every licensed virtual asset service provider across VARA, ADGM, DIFC, CBUAE and the SCA/CMA is a useful tool — but its very existence exposes how fragmented, and how easy to get wrong, UAE crypto licensing verification has become.

Five regulators, no single register

The UAE regulates virtual assets through overlapping but distinct regimes rather than one federal licensing authority. The Virtual Assets Regulatory Authority (VARA) governs virtual asset activity across Dubai (excluding the DIFC). The Dubai Financial Services Authority licenses virtual asset business conducted from within the DIFC. The Financial Services Regulatory Authority does the same for the ADGM in Abu Dhabi. The Central Bank of the UAE (CBUAE) licenses payment token issuance and stored-value activity that touches the payments system. And the Securities and Commodities Authority (SCA) retains federal jurisdiction over onshore activity in the other emirates, and over tokens that qualify as securities or commodities wherever they are offered. A single business model — say, a token issuance with a payment function marketed nationally — can touch three or four of these regulators simultaneously, each with its own licence categories, marketing rules and enforcement powers.

NeosLegal's newly launched tracker, aggregating licensed VASPs across all five regimes into one reference point, is a sensible market response to that fragmentation. It is also a useful diagnostic: the fact that a private tracker is newsworthy tells practitioners something about the state of public verification tools. There is no single, authoritative, real-time federal register a counterparty, bank or investor can check to confirm licensing status across the whole UAE. Verification means checking VARA's public register, the DFSA and FSRA registers separately, and cross-referencing SCA and CBUAE announcements — a process most commercial teams do not do properly, and one that increasingly matters.

Why the gap is not academic

VARA's marketing regulations prohibit the promotion of virtual asset products and services in or from Dubai without a VARA licence or a specific exemption, and the prohibition binds not just issuers but intermediaries, influencers and platforms that facilitate the marketing. A UAE-based fund, exchange introducer or corporate treasury team that engages an unlicensed counterparty, or promotes an unlicensed product to UAE clients, is exposed regardless of where the counterparty is actually based. The same logic applies in reverse: a business licensed in the DIFC or ADGM has no automatic passport to solicit clients onshore in Dubai or Abu Dhabi without separately satisfying VARA or SCA requirements. Licence scope is jurisdictionally and product-specifically narrow, and assuming equivalence between regimes is a recurring source of inadvertent breach.

Assuming that a licence in one UAE jurisdiction travels to another is the single most common — and most avoidable — compliance error in this sector.

The due diligence discipline this demands

• Counterparty verification: confirm the specific licence category held (custody, exchange, broker-dealer, advisory, issuance) against the specific activity being conducted, not just the fact of licensing somewhere in the UAE.
• Jurisdictional scope: establish whether the licence permits onshore marketing, free-zone-only activity, or cross-border solicitation, and whether SCA or VARA consent is separately required for onshore reach.
• AML/CFT registration: confirm the entity is registered on the UAE's goAML platform and meets the risk-based obligations applicable to VASPs under the federal anti-money laundering framework, which sits alongside — not instead of — sectoral licensing.
• Product characterisation: where a token has features resembling a security, commodity or payment instrument, check whether SCA or CBUAE jurisdiction is also engaged, since VARA licensing alone will not cover those overlaps.

The strategic picture

For new entrants choosing where to establish — VARA, ADGM or DIFC — the decision is no longer purely about regulatory tone or cost. It is about which regime's licence categories map onto the actual product, which onward marketing rights are needed, and which supervisory relationship the business can sustain at scale. For banks, funds and payment institutions onboarding crypto-adjacent counterparties, the practical lesson from tools like this tracker is that licence verification deserves the same rigour as corporate KYC — checked at source, jurisdiction by jurisdiction, and refreshed, because licence scope and status change. The UAE's multi-regulator model gives it flexibility and competing centres of excellence; it also places the verification burden squarely on practitioners rather than on any single public authority.

Key instruments: VARA regulations (including marketing regulations) for Dubai; DFSA rulebook (DIFC); FSRA regulations (ADGM); CBUAE licensing framework for payment tokens and stored value; SCA/CMA federal securities and commodities regulations; UAE federal AML/CFT law and goAML registration requirements. General information, not legal advice.