The Dubai Virtual Assets Regulatory Authority issued a circular to all virtual asset service providers (VASPs) it licenses or authorises, setting out supervisory expectations for implementing the UAE Virtual Asset Travel Rule for qualifying virtual asset transfers. The Travel Rule establishes mandatory requirements for collecting, verifying, securely transmitting, monitoring, and retaining Originator and Beneficiary information, and VASPs must not execute a qualifying transfer unless the applicable requirements are met. The circular clarifies that the Travel Rule applies across the territorial scope of UAE federal and Emirate laws, including Free Zones and Financial Free Zones, while explicitly excluding transaction fees, including "gas fees". “Executing” a transfer is interpreted broadly to include initiating, facilitating, effecting, or otherwise materially contributing to a transfer. Operational expectations cover the required data to accompany each transfer, including within batched transfers, and allow limited data transmission for certain domestic transfers where full verified data is otherwise available, provided the full dataset can be made available within three working days upon request. VASPs must also confirm that counterparty VASPs are appropriately regulated and must not transfer to unregulated counterparties, implement risk-based handling of missing or incomplete information, and document and report systemic counterparty failures to provide required information. For transfers with daily aggregated amounts of AED 3,500 or more, Beneficiary identity verification is required where the Beneficiary has not been previously verified. Additional requirements address intermediary provider obligations, enhanced due diligence for transfers involving unhosted wallets, suspicious transaction reporting to the UAE Financial Intelligence Unit where thresholds are met, and a prohibition on executing transfers involving privacy tokens. VASPs are expected to update relevant policies, procedures, systems, controls, and staff training to align with the Travel Rule and applicable VARA rulebooks, with VARA assessing implementation through supervisory engagements, inspections, and thematic reviews. The Travel Rule applies in line with commencement provisions in Cabinet Decision No. 134 of 2025, and VARA indicated it may issue further guidance or directives to support consistent implementation.
Dubai Virtual Assets Regulatory Authority 2026-02-24
Dubai Virtual Assets Regulatory Authority issues Travel Rule implementation circular for VASPs including AED 3,500 verification trigger and privacy token transfer ban
The Dubai Virtual Assets Regulatory Authority issued a circular to virtual asset service providers (VASPs) detailing supervisory expectations for the UAE Virtual Asset Travel Rule. The rule mandates data collection, verification, and transmission for qualifying transfers, prohibiting non-compliant transfers. VASPs must ensure counterparties are regulated, manage incomplete information, and report systemic failures, with additional obligations for transfers involving unhosted wallets and privacy tokens.