VARA licenses a defined list of activities: advisory services, broker-dealer services, custody, exchange services, lending and borrowing, management and investment services, transfer and settlement services, and the issuance of virtual assets. A virtual asset service provider must hold a licence for each activity it carries on in or from Dubai, outside the DIFC. Some businesses, such as pure software developers or those dealing only in assets outside VARA's definition, may fall outside the regime, but that requires careful analysis. We map the proposed business against the activity definitions and the current rulebooks before an application is prepared or submitted.

Nationality alone does not prevent a Bangladeshi citizen from owning or managing a VARA-licensed virtual asset service provider, but VARA will assess the suitability of shareholders, controllers, directors and senior managers, including their source of funds and wealth, experience and reputation. A Bangladeshi resident shareholder must also consider Bangladesh law: sending capital abroad for an overseas investment generally requires Bangladesh Bank approval, and holdings and income may need to be disclosed in Bangladesh tax returns. We advise on both sides, so that the ownership structure is acceptable to VARA and lawful under Bangladesh foreign exchange rules.

This is one of the most sensitive questions for Bangladesh-linked businesses. Bangladesh Bank has warned the public that virtual currency transactions are not authorised and may breach foreign exchange and anti-money laundering laws, and there is no Bangladesh licensing regime for crypto exchanges. A Dubai licence does not authorise activity in Bangladesh. Actively marketing to, onboarding or accepting funds from Bangladesh residents can create legal risk for the firm, its founders and the customers. We advise on geographic restrictions, IP and document checks, onboarding controls and marketing policies that reflect the Bangladesh position and VARA's own expectations.

Timing for a virtual asset service provider application depends on the activities sought, the quality and completeness of the application, the applicant's ownership and governance, and how quickly it responds to VARA's questions. The process includes the commercial licence stage, VARA's staged assessment and any conditions that must be satisfied before the firm can begin operating. Applications with complex ownership, unusual products or weak documentation take longer. We help clients prepare a realistic plan and complete the documents before submission, but we do not promise timelines that depend on the regulator's review and discretion.

VARA sets capital requirements by activity, often combining a minimum paid-up capital amount with a requirement linked to operating expenses, and may require insurance or additional reserves. Requirements differ, for example, between an advisory firm and an exchange or custodian. Because VARA updates its rulebooks, we check the current requirements for each activity before an application is planned. For Bangladesh-based founders, raising and transferring this capital lawfully is a practical issue in itself, as outward remittance for overseas investment generally requires Bangladesh Bank approval and complete supporting documentation, so the capital plan should be settled before the application is filed.

Many virtual asset service provider groups use development or support teams in Bangladesh, which has a large technology workforce. This can be done lawfully, but the arrangement needs care. VARA expects licensees to maintain control over outsourced functions, with proper agreements, oversight, data protection and security. In Bangladesh, the local entity should be structured as a software or IT-enabled services company that does not itself deal in, promote or facilitate virtual asset transactions. Service agreements, transfer pricing, tax, data protection under the Personal Data Protection Act 2026 and employment terms should all be addressed in writing.

VARA licensees must implement a risk-based anti-money laundering and counter-terrorist financing programme under UAE federal law and VARA's compliance rulebook. That includes customer due diligence and enhanced checks for higher-risk customers, sanctions screening, transaction and blockchain monitoring, travel rule data exchange for transfers, record keeping, staff training, a qualified compliance officer and money laundering reporting officer, and reporting suspicious transactions to the UAE Financial Intelligence Unit. Bangladesh-linked customers and flows may need a specific risk assessment that reflects local remittance channels and typologies. We help design controls and review them against the rules and the real customer base.

VARA can issue warnings, impose fines, require remedial action, restrict activities, and suspend or revoke licences, and it has published enforcement outcomes against firms operating without a licence or breaching marketing rules. A virtual asset service provider facing an inquiry should preserve records, respond accurately and promptly, and take legal advice before making admissions. Where a Bangladesh-linked founder or customer is involved, the matter may also raise questions under Bangladesh law. We coordinate the response with Dubai counsel, assess any Bangladesh exposure and advise on remediation and any review or appeal that may be available.