Yes. VARA regulates virtual asset activities in Dubai outside the DIFC, while the DFSA regulates financial services in or from the DIFC, including those involving digital assets. The DFSA regime distinguishes investment tokens, treated like traditional securities or derivatives, from crypto tokens, which are subject to specific rules on permitted tokens, custody and disclosure. The licensing structure, capital rules, supervisory approach and legal system differ, with the DIFC applying its own common law framework. A business should choose its base after comparing the regimes against its products, target clients, investors and banking needs, rather than on cost alone.

An Innovation Testing Licence is a DFSA authorisation that allows eligible firms to test innovative financial products or services within the DIFC under restrictions, such as limits on client numbers or exposure, for a defined period. It is designed for genuinely new propositions rather than as a cheaper permanent licence. Applicants must still show suitable governance, controls and resources, and must plan how they will move to full authorisation or exit when testing ends. We advise on whether a digital assets proposition is likely to be eligible and on preparing a credible testing plan that the DFSA can assess.

A Bangladeshi bank or non-bank financial institution would need to consider Bangladesh Bank approval for any overseas investment or establishment, its own licence conditions and Bangladesh's position on virtual currencies, which is restrictive. Activities involving tokenised traditional assets may be treated differently from crypto token activities, but each requires analysis under Bangladesh law before any step is taken. On the DIFC side, the DFSA will review the parent's regulatory status and home-state supervision. We advise financial institutions on both regulatory sides and on the approvals sequence, so that the project does not breach Bangladeshi rules.

The DFSA restricts the crypto tokens that authorised firms may use in their services, applying criteria such as regulatory status in other jurisdictions, transparency, liquidity, market size and the technology involved. Privacy tokens and algorithmic stablecoins have been excluded. The DFSA's approach to deciding which tokens may be used has evolved, and firms may have their own assessment responsibilities as well as relying on any regulator list. Because this area changes, we check the current DFSA rules and policy before a firm commits to supporting a particular token or launching digital assets products around it.

Timing depends on the complexity of the business, the licence categories sought, the applicant's ownership and controllers, the completeness of the application and how quickly questions are answered. DIFC company registration, regulatory review, approval of individuals and pre-launch conditions all form part of the overall timeline. Firms entering through a testing route may move faster initially but must plan for transition. We help clients assemble complete applications for digital assets and fintech businesses and respond efficiently, and give realistic planning guidance, but we do not guarantee timelines that depend on the regulator's review and its supervisory priorities at the time.

Authorisation in the DIFC does not permit activity in Bangladesh. Bangladesh Bank has warned that virtual currency transactions are not authorised and may breach foreign exchange and anti-money laundering laws, and cross-border investment by Bangladesh residents is controlled. Offering services to Bangladeshi residents can therefore create legal risk for the firm, its founders and its customers, even if the service is lawful under DFSA rules. Tokenised traditional assets raise their own securities and foreign exchange questions in Bangladesh. We advise on onboarding restrictions, marketing controls and the Bangladesh analysis for each product.

Capital requirements depend on the firm's prudential category, which reflects its activities, such as whether it holds client assets, deals as principal or only arranges or advises. Firms also need adequate liquidity, professional indemnity insurance in some cases, and sufficient staff and systems, including approved individuals for key functions such as senior executive, finance, compliance and money laundering reporting. Firms dealing in digital assets face additional expectations on technology governance and custody. We help clients understand the requirements for their category and present resources credibly in the application.

Client agreements with DIFC firms often choose DIFC law and the DIFC Courts, or arbitration. The DIFC Courts apply a common law approach, and their judgments can be enforced onshore in Dubai and potentially abroad, depending on the destination's rules. Where a Bangladeshi counterparty or assets in Bangladesh are involved, enforcement needs separate analysis, because foreign judgments and arbitral awards follow different routes, and Bangladesh is a party to the New York Convention for awards. We advise on dispute clauses at the outset and on enforcement strategy when a dispute arises, including against digital assets held on exchanges.