Legal Insights
TL;DR:
In a public enforcement notice issued earlier this week, Dubai’s Virtual Assets Regulatory Authority (VARA) announced penalties against 19 entities for breaches of its regulatory framework. This includes both unlicensed virtual asset activity and violations of marketing regulations.
These enforcement actions were taken over the past six months. They reflect VARA’s intent to close long-standing gaps in compliance and reinforce a clear position: conducting regulated activities in Dubai without a VARA license is unlawful, and all marketing must comply with VARA’s Marketing Regulations.
According to Unlock Media, the enforcement actions affected both global and locally established firms:
- Triple A Technologies (Singapore) was fined for offering unlicensed virtual asset services in Dubai despite local partnerships.
- LBK Blockchain FZCO (LBank) was sanctioned for both unlicensed operations and marketing to users in Dubai.
- Several local platforms were also penalized, including Hokk Finance, Hatom Labs, Paycio, and AirDance Global. These cases demonstrate that Dubai free zone incorporation does not eliminate the requirement for VARA licensing.
Penalties ranged from AED 100,000 to AED 600,000. In one case, VARA appointed an independent reviewer to assess the company’s compliance systems.
VARA Now Enforcing Marketing Regulations
Previously, VARA’s enforcement was mainly directed at operational activity. These recent actions show that marketing alone can trigger regulatory penalties if conducted without prior approval.
Any entity referencing Dubai in its promotional materials or actively targeting users in the Emirate must comply with the Marketing Regulations under VARA’s regulatory framework.
Misunderstanding the Scope of Regulation Is a Risk
Some firms assume their business model does not fall under VARA’s scope. Others rely on licenses from foreign jurisdictions and mistakenly believe these are sufficient.
They are not. Any activity targeting users in Dubai, whether promotional or operational, must be assessed for licensing requirements under VARA.
Conclusion
VARA is actively enforcing compliance. The recent sanctions confirm that Dubai is not a market where regulatory shortcuts are tolerated. For any virtual asset business intending to engage with the Dubai market, regulatory approval is not optional. It is a legal prerequisite.
Earlier in 2025, VARA had reportedly already issued fines against several entities for violations of its Marketing Regulations, particularly in connection with unauthorized promotional activities at public events. Separate actions were also taken against certain VASPs, though in many cases the exact nature of the violations was not publicly disclosed.
Taken together with the latest wave of enforcement, these measures form a clear trend. VARA is systematically tightening oversight and increasing scrutiny across the sector. Based on current activity, enforcement is expected to intensify further.
In this regulatory environment, it is essential for virtual asset businesses to obtain legal advice before entering or engaging with Dubai’s market. A proper legal and regulatory assessment can identify licensing triggers, reduce exposure, and help ensure compliance with VARA’s detailed framework. Failure to do so may result in significant penalties, reputational harm, and loss of access to one of the region’s most important virtual asset jurisdictions.
Book a consultation with our lawyers to make sure your promotional and operational activities are 100% compliant with VARA regulations.
