VARA – Initial Disclosure Questionnaire (IDQ)

All companies planning to undertake Virtual Assets related activities in the Emirate of Dubai, are required to complete this Initial Disclosure Questionnaire ("IDQ") in its entirety and submit it to Dubai’s Virtual Assets Regulatory Authority (“VARA”). Please note that only submissions (including supporting documents and attachments) in English language will be accepted at this stage.



Please note that questions marked with an asterisk (*), are mandatory.



Capitalised terms used but not defined herein shall have the same meaning ascribed to them in the relevant rulebooks published by VARA.


SMS containing OTP has been sent to your mobile
*Please complete mandatory questions to proceed.
Company Details
Q.0
Company Legal Name

Please provide the registered or proposed full legal name of the company.

Q.0
Company incorporation status

Please provide details of the company's incorporation status in the Emirate of Dubai. (Has the company received a valid and full trade licence)

Q.0
Company incorporation detail

Please indicate where your company is currently or will be incorporated/established in:

a. if it is a Dubai mainland company, please select DET.

b. if it is in a Dubai freezone, please select the relevant freezone the company is or will be incorporated/established in.

Q.0
Registered office address

i. Please provide the full details of the company's current or planned registered office address (as it will appear on the official Trade Licence).

ii. If the company will primarily operate from an office address that is different from the registered office address, please also provide the full details of that address.

Q.0
Operational status

Are your currently offering/undertaking any Virtual Asset products/services in and from the Emirate of Dubai? 

Have you begun any business or activity which includes crypto/virtual assets?

Q.0
Consultant/Third Party Declaration

Please clarify and confirm if you are a consultant/corporate service provider/third party completing this form on behalf of your client (the applicant).

Q.0
Signed letter of Authorisation

If you are a consultant, corporate service provider or third party representing the applicant that is applying for VARA approval (VASP Licence or No Objection Confirmation ("NOC")), please provide a signed letter from your client, authorising you or your company (as applicable) to represent your client to VARA.

 

Please note that VARA will not liaise with any third parties that do not provide such authorisation.

Pdf: Maximum size 1 Mb
Q.0
Individual completing the form

Please provide the following details:

Q.0
Trade licence number 

Please provide the company's current trade license number (if applicable).

If the company does not yet have a trade licence, please respond with 'N/A'

Q.0
Trade licence copy

Please provide a copy of your current trade licence (if applicable).

Pdf: Maximum size 1 Mb
Q.0
Company Website

Please clarify the following queries:

Q.0
Total number of employees

Please clarify the following queries

Q.0
Company Organisational Structure Diagram

Please provide a comprehensive and clear organisational structure diagram for the company. This must detail all C-Suite, Senior Management, Board of Directors (if any) and reporting lines.

Image: Maximum size 1 Mb
Pdf: Maximum size 1 Mb
Docx: Maximum size 1 Mb
Q.0
Company ownership details

For each individual(s) that own 10% or more of the company, please provide:

i. full name (as they appear on valid official ID);

ii. primary email address(es);

iii. date of birth;

iv. primary residential address;

v. valid primary contact number; and

vi. ownership details of all individuals that own 10% or more of the company (either directly or indirectly).

Q.0
Register of Members

If the company is already incorporated in the Emirate of Dubai, please provide an official and up-to-date Register of Members/shareholders (or equivalent document such as Memorandum of Association, Articles of Association) issued and/or validated by the commercial licencing authority that details all current shareholders and owners of the company, and their ownership details (including % ownership details)

Pdf: Maximum size 1 Mb
Q.0
Ownership Structure Diagram

Please provide a clear company ownership strucutre diagram for the company that details all owners, shareholders and UBOs of the company. If there are any parent entities, please provide a clear structure diagram setting out all holding companies that are involved in the ownership structure of the company.

Image: Maximum size 1 Mb
Pdf: Maximum size 1 Mb
Docx: Maximum size 1 Mb
Q.0
Company owners primary proof of ID

Please provide a single, consolidated PDF document with a copy of the valid primary passport and, if applicable, the valid Emirates ID for all individuals that own 10% or more of the company.

Pdf: Maximum size 1 Mb
Image: Maximum size 1 Mb
Q.0
Company owners additional proof of ID (if applicable)

If the company owners possess dual or multiple citizenships, Please provide a single, consolidated PDF document with a copy of the additional passports for each applicable individual (as applicable)

Pdf: Maximum size 1 Mb
Image: Maximum size 1 Mb
Q.0
Company Owners CVs

Please provide a single, consolidated PDF document with clear, accurate and detailed CV/Resumes for ALL company owners (that own 10% or more of the company).

Please ensure the CVs contains all relevant work and professional experience detail for each individual for the last 10 years at minimum.

Pdf: Maximum size 1 Mb
Docx: Maximum size 1 Mb
Q.0
CEO/Managing Director details

For the appointed company CEO or Managing Director, please provide:

Q.0
CEO/Managing Director primary proof of ID

Please provide a single, consolidated PDF document with a copy of the valid primary passport and, if applicable, the valid Emirates ID for the CEO/Managing Director.

Pdf: Maximum size 1 Mb
Image: Maximum size 1 Mb
Q.0
CEO/Managing Director additional proof of ID (if applicable)

If the CEO/Managing Director possess dual or multiple citizenships, Please provide a single, consolidated PDF document with a copy of the additional passports (as applicable)

Image: Maximum size 1 Mb
Pdf: Maximum size 1 Mb
Q.0
CEO/Managing Director CV

Please provide a single, consolidated PDF document with clear, accurate and detailed CV/Resumes for the CEO / Managing Director of the company

Please ensure the CVs contains all relevant work and professional experience detail for each individual for the last 10 years at minimum.

Pdf: Maximum size 1 Mb
Docx: Maximum size 1 Mb
Q.0
Close links details

Please declare any close links (either business relationship, common ownership, other control arrangements) the company has:

Fit & Proper Declarations
Q.0
Company owner(s) individual conduct disclosure

In case any of the company owners and/or shareholders currently have or have had:

Please provide comprehensive details on each instance, where applicable.

Q.0
Company Senior Management individual conduct disclosure

In case any of the company senior management and/or c-suite currently have or have had:

Please provide comprehensive details on each instance, where applicable.

Q.0
Legal Entity, Parent Entity and Group Entity(ies) conduct disclosure

In case the company, its parent entity(ies), related entities and group entities currently is or was:

Please provide comprehensive details on each instance, where applicable.

Business Activities
Q.0
Business model overview

Please provide a detailed overview and summary of the company's business model, including the Virtual Asset activity(ies) or service(s) your business currently, or plans to, undertake, your target customer base, and your revenue model.

Q.0
Business plan

Please provide a clear, accurate and up-to-date regulatory business plan (in English and in PDF format) for the company. The regulatory business plan document must detail at minimum:

 

i. the company details, including the history of the company and its parent company and group (if applicable);

ii. the ownership structure (including UBOs);

iii. an overview of its nature of operations and its presence regionally and/or globally;

iv. the rationale for entering the UAE market and doing business in Dubai;

v. a comprehensive and detailed description of all activities, products and services planned to be undertaken by the company, in the Emirate of Dubai;

vi. how each Virtual Assets related activity, product and service will be carried out, and provide a clear and comprehensive flow of funds diagrams that describes the end-to-end flow of funds (both fiat and Virtual Assets) including any related parties and counterparties;

vii. detailed timelines for each Virtual Assets related activity, product, and service to be launched (e.g. product roadmap);

viii. details on how the company intends to acquire new customers, including the channels it will use for its marketing activities;

ix. details on the target client population and demographic it has identified, with a prospective total number of projected customers broken down per investor classification (institutional investors, qualified investors, and retail investors) for the first two years of operations; and

x. details on how the company will generate revenue from each Virtual Assets related activity, product and service.

 

Please note that your IDQ submission may be rejected in its entirety if the submitted business plan does not meet or satisfy the above requirements.

Pdf: Maximum size 1 Mb
Docx: Maximum size 1 Mb
Q.0
Virtual Asset activities

Please select which of the following Virtual Asset activities the company currently, or plans to, undertake (tick all that apply).

 

Please ensure you have reviewed in detail the VARA website (VARA Licensed Activities) for a description of each of the below activities, as well as the FAQ section if necessary.

 

Please note that the activity of VA Issuance requires approval from VARA, and the activity of VA Proprietary Trading requires a registration with VARA. All other VA activities require a VASP Licence. Distributed Ledger Technology Services requires a Non-objection Confirmation ("NOC") from VARA.

 

Please note that VA Custody Services and VA Proprietary Trading (marked with an asterisk (*)), are stand-alone, and cannot be combined with any other activity. They can only be offered through separate, individually licensed, entities.

Q.0
VA Proprietary Trading

Please answer all of the below questions:

Q.0
Virtual Assets Issuance

If you are planning to issue any token or Virtual Asset (including stablecoins, Real World Assets ("RWAs") token etc.) in or from the Emirate of Dubai, please detail the following:

 

Additionally please note you are required to seek prior approval from VARA, in order to carry out such issuance activity. Please kindly reach out to us via email on issuance@vara.ae and copy licensing@vara.ae.

Q.0
Other Virtual Asset activity 

Please provide a clear and detailed description on the current or planned other virtual asset activities which the company offers. 

Q.0
Virtual Asset Payments Services

Please confirm below if you currently offer or plan to offer any virtual asset/crypto payment services.

 

Kindly note that all virtual asset/crypto payment services need separate approval from the UAE Central Bank, and that you must obtain all such approvals from such institution prior to being eligible for any VASP Licence from VARA.

Q.0
Target customers

Please select which type of customers the company currently / plans to serve (select all that apply).

 

Note: if you are a VA Proprietary Trading firm with no current or planned customers or clients at all, please select the option accordingly. 

Q.0
Number of customers

Please clarify the below queries;

Financial Information
Q.0
Company financial position

Please provide a clear and accurate overview of the company's total current assets and liabilities (including virtual assets, fiat assets, and all other holdings in the name of the company). If the company does not have any assets or liaiblities at all, please clarify the same. Please provide all figures in either AED or USD.

Q.0
  • Financial projections

Please attach a copy of your forecast financial projections for the company over the next 3 years (in AED or USD, including current year and the first year of operations):

i. please note the financial projections you submit must be aligned and consistent with the business plan and business model overview of the company;

ii. for each year, please kindly provide the total forecast revenue and total forecast expenses; and

iii. please ensure the total forecast revenues and expenses include breakdowns of all line items as well.

Pdf: Maximum size 1 Mb
Docx: Maximum size 1 Mb
Q.0
Source of funds

Please explain and provide details on your source of funds for the company, including details on:

Business Undertakings
Q.0
Please read each of the below statements and tick the relevant box on behalf of the company to confirm you have understood the statement and undertake to abide by it:
Q.0
Signature of individual completing the form

Please write your full name name here as a signature to the above undertakings on behalf of the company.

Q.0
Date of Signature

Please provide the date of signature to the above undertakings.

Powered by The Telecommunications and Digital Government Regulatory Authority