01
Perimeter & licensing strategy
Map the proposed activities to the applicable regulatory perimeter before structuring the application, operating model or market-entry plan.
Regulatory strategy · virtual assets · MENA
Regulatory clarity for the next phase of digital finance.
Cryptos Consultancy advises virtual asset businesses, financial institutions and technology-led firms on licensing strategy, AML/CFT, governance and regulatory operating models across the UAE and selected MENA markets.
Executive lens
Regulation is now an operating model.
For a board, CCO, MLRO, CTO/CIO or regulatory-reporting function, the question is no longer simply where to obtain permission. It is how the business model, controls, technology and governance remain aligned with the perimeter after authorisation.
02
Financial crime & controls
Translate AML/CFT, sanctions, risk-assessment, KYC/CDD and monitoring requirements into documented controls that can operate in practice.
03
Governance & regulatory readiness
Build accountability, policies, reporting lines, technology controls and evidence trails around supervisory expectations rather than minimum-form compliance.
Dubai focus
VARA terminology matters.
The Dubai framework is activity-based. VARA distinguishes mandatory rulebooks applicable to all VASPs from rulebooks specific to the VA Activities for which a VASP is licensed.
Compulsory rulebooks
Company · Compliance & Risk Management · Technology & Information · Market Conduct
Each sits alongside the activity-specific requirements applicable to the VASP's licensed VA Activities.
Licensed VA Activities
Advisory · Broker-Dealer · Custody · Exchange · Lending & Borrowing · Management & Investment · Transfer & Settlement · Category 1 VA Issuance
Applications and permissions must be assessed against the actual activity set rather than a generic “crypto licence” concept.
Regulatory intelligence
What changed in 2026.
16 Jul 2026
FATF: seventh targeted VASP update
FATF’s latest targeted update reviews implementation of Recommendation 15 across the Global Network and highlights remaining gaps in virtual asset/VASP regulation and supervision.
21 May 2026
ADGM strengthens its AML framework
FSRA finalised enhancements covering AML, counter-terrorist financing, counter-proliferation financing and sanctions compliance, with the updated AML Rulebook published in May 2026.
12 Jan 2026
DFSA updates its Crypto Token regime
For DIFC financial services activities involving Crypto Tokens, firms now carry direct responsibility for documented suitability assessment under the updated regime.
Reference centre
A structured reference for the regulatory perimeter.
Our Regulatory Intelligence Centre consolidates verified regulator terminology, the principal rulebooks and the key distinctions between Dubai, ADGM, DIFC and Bahrain. The baseline is reviewed against official sources through 31 August 2026.