The Dubai Virtual Assets Regulatory Authority issued a circular reminding all Virtual Asset Service Providers (VASPs) operating in Dubai’s mainland and commercial free zones to strictly comply with Anti-Money Laundering and Combatting Financing of Terrorism and Financing of Illegal Organizations (AML-CFT) requirements under the UAE federal framework, alongside VARA’s own rulebooks. The notice reiterates that, under Rule III.B.1 of VARA’s Compliance and Risk Management Rulebook, VASPs must have robust policies and procedures covering all applicable AML-CFT obligations, including federal laws currently in force and any future amendments. VASPs are expected to identify all relevant federal requirements applicable to their activities, including federal AML-CFT laws, Cabinet Decisions, Executive Regulations, regulatory guidance, and obligations set by competent authorities such as the Executive Office for Control and Non-Proliferation. Based on this analysis, firms must implement risk-based policies and controls, ongoing monitoring processes, and mechanisms to incorporate new requirements, with regular updates reflecting legal changes, new guidance, and emerging virtual asset sector risks. The circular also highlights Rule III.G (Travel Rule) requirements for transfers of virtual assets exceeding AED 3,500, including collecting and retaining required originator and beneficiary information, making it available to VARA or other authorities upon request, and conducting risk-based due diligence on counterparty VASPs; non-compliance may lead to enforcement action under VARA regulations and federal AML-CFT laws.