The Dubai Virtual Assets Regulatory Authority (VARA) has released a Circular addressed to all Virtual Asset Service Providers (VASPs) outlining Enhanced Measures for High‑Risk Jurisdictions. This update follows the October 2025 Financial Action Task Force (FATF) list revision and the UAE National Committee’s Decision No. (15) of 2025. The measures take immediate effect and form part of the UAE’s ongoing effort to strengthen its AML/CFT/PF regulatory framework.
Key required actions for VASPs
- Risk assessments: Incorporate FATF high‑risk and increased‑monitoring jurisdictions into internal risk assessments and control frameworks, with explicit consideration of money laundering, terrorist financing, and proliferation financing risks.
- Enhanced due diligence: Apply enhanced due diligence for all customers, transactions, and relationships linked to high‑risk jurisdictions. This includes:
- Verification of identity and beneficial ownership.
- Source of funds and source of wealth checks.
- Assessment and justification of the business relationship.
- Enhanced ongoing monitoring and reporting to the Financial Intelligence Unit where required.
- Prohibitions:
- Establishing branches or representative offices in FATF black‑listed jurisdictions.
- Reliance on third‑party customer due diligence providers located in those jurisdictions.
- Policy Updates: Amend internal policies, procedures, and customer risk‑classification methodologies to reflect these enhanced requirements.
Supervisory oversight
VARA will review compliance through inspections, thematic reviews, and regulatory reporting. Non‑compliance may lead to enforcement action under applicable federal laws and VARA regulations.
This Circular reaffirms the UAE’s commitment to shoring up defenses against cross‑border financial crime and aligning the virtual asset sector with global regulatory best practice.