Dubai is attractive for crypto operators because it pairs ambition with structure: a regulator that speaks the industryâs language and counterparties that recognize the signal. If youâre scoping a launch or a migration, hereâs a straight-through read on model choices, evidence reviewers want to see, and the sequencing that keeps v1 moving. For the official route and requirements, see Dubai VARA license.
The one-page story that actually gets read
Before you draft a single policy, write the one-pager that will live in every diligence pack: what you do, who you serve, which assets and corridors youâll support in v1, and how money (or tokens) flow from onboarding to withdrawal. If that page is plain and consistent with your site and contracts, youâve already cut half the back-and-forth most teams suffer.
Model decisions that define your burden
Non-custodial tooling is lighterâuntil you embed routing, matching, or settlement. Custodial wallets and exchanges draw the full spotlight: key governance, withdrawal controls, reconciliation, Travel Rule coverage, market conduct if you list assets. Payments/on-ramps live or die on sanctions, source-of-funds, and counterparties that wonât embarrass you. Keep v1 narrow (spot, simple listings, no leverage) and say so out loud; scope creep is what turns tidy reviews into marathons.
How to talk âcustodyâ without hand-waving
A reviewer isnât looking for poetryâjust proof. Describe where keys live (HSM or audited multisig), who can approve movements (roles, not names), how withdrawals are gated (dual approvals, velocity limits, allow-lists for higher-risk cohorts), and how you reconcile (daily or weekly, signed off by whom, stored where). Include one screenshot of an approval log and one extract of a reconciliation. Thatâs worth ten pages of adjectives.
Travel Rule: show, donât promise
Pick an interoperable provider early and wire your main corridors. Capture three or four message tracesâsuccess, non-participant, and failover behavior. Drop those into your evidence pack. âWeâll implement laterâ is how you buy a month of clarifications.
Governance that looks like you mean it
Name a Compliance Officer with a direct line to the board (or top management) and document that appointment in minutes. Keep a clean UBO chart and a brief âfitness and proprietyâ packet for controllers (IDs, addresses, short CVs). Approve your policy suite via dated resolutions. Nothing fancyâjust decisions that can be shown, not reconstructed.
Mini case: the overbuilt exchange that learned to start small
A team arrived with an all-singing exchange: spot, margin, futures, staking, complex listings. Banking was nervous; reviewers had 40 questions. They pivoted: trimmed to spot pairs, paused leverage, reduced listed assets to a handful with clear liquidity and disclosures, and shipped Travel Rule with real traces. Clarifications dropped to four questions. Accounts opened. The lesson isnât âthink smallââitâs âsequence big.â Launch the base model credibly, then add features in public, with minutes and policy updates that match reality.
Bank-ready without drama
Banks and PSPs ask the same four things on repeat. Who owns and runs this business (with evidence)? What exactly do you do (in language an accountant understands)? How do funds move (corridors, volumes, counterparties, currencies)? How do you keep illicit flows out and client assets safe (segregation, monitoring, approvals, reconciliations)? Put the answersâplus a simple flow diagram and two or three screenshotsâin a tidy folder you can share at a momentâs notice. Onboarding then feels routine, not theatrical.
Documents that move the needle
Youâll assemble the corporate basicsâarticles, registers, org chart, IDs and addresses for directors and UBOs, short CVs, a realistic business planâbut what accelerates reviews is evidence: a sanctions-hit handling screen, an onboarding risk rating output, a sample monitoring alert with analyst notes, a withdrawal approval record, and a reconciliation excerpt. Keep everything dated and searchable.
Sequencing that keeps momentum
Week 1â2: map flows (onboarding â funding â action â withdrawal), decide custodial vs non-custodial, pick vendors (KYC/KYB, Travel Rule, custody tooling), and write the one-pager. Week 3â5: draft AML/CTF, sanctions, monitoring, custody, security, and client disclosures tied to those flows; appoint the Compliance Officer; capture your evidence screenshots and logs. Week 6+: file a complete pack and answer clarifications with short, screenshot-backed replies. In parallel, open a fintech-friendly EMI/PSP so you can invoice and operate; add a bank or second EMI when the base is stable.
Common failure modes (and the fix)
Policyâproduct mismatch (âmanuals say we have allow-lists, app doesnâtâ). Vague activity narrative (âcrypto platformâ) that contradicts your UI. UBO proof that looks improvised. Travel Rule âlater.â The fix is boring and effective: write from screenshots, keep the story consistent everywhere, and only claim whatâs in production or scheduled with a date.
Pricing reality: budget by buckets
There isnât a single âlicense feeâ that explains your runway. Think in three buckets: one-off setup (advisory, policy build, application prep), technology & security (KYC/KYB, Travel Rule, custody, monitoring stack, pen-testing), and ongoing compliance (officer time, audits, reporting, training, renewals). Under-resourcing shows up as gaps; gaps are what slow approvals and bank onboarding.
Final operator notes
Keep v1 honest and tight; evidence beats adjectives; and every promise needs an artifact (log, screen, minute). If youâd rather have an experienced team run the filings and assemble the bank-ready pack while you ship product, LegalBison typically leads the heavy liftingâdetails at legalbison.com.