Anti-Money Laundering for Crypto Assets Under Dubai's VARA Model and Lessons for the Vietnam International Financial Centre (VIFC) (Zenodo (CERN European Organization for Nuclear Research))

Summary

• As of October 1, 2026, VARA's public register recorded 56 licenses issued under Dubai's specialized virtual asset regulatory framework.p.2
• VARA mandates Customer Due Diligence for occasional transactions starting at 3,500 AED, compared to 55,000 AED for general financial institutions in the UAE.p.5
• Federal law in the UAE penalizes unlicensed virtual asset operations with fines ranging from 200,000 to 10,000,000 AED alongside potential penal sanctions.p.7
• Under Resolution 05/2025 in Vietnam, pilot market licensing eligibility requires a minimum charter capital threshold of VND 10,000 billion.p.8
• Decree No. 284/2026/ND-CP sets administrative fines in Vietnam to a maximum of VND 200 million for organizations and VND 100 million for individuals.p.8
• In October 2025, VARA fined 19 entities between 100,000 and 600,000 AED for unlicensed operations and marketing violations.p.7

Key insights

1. VARA operates as an independent specialized authority established under Dubai Law No. 4 of 2022 to govern virtual asset activities.p.1
2. The removal of the UAE from the FATF grey list in February 2024 demonstrated international recognition of its evolving regulatory framework.p.2
3. VARA mandates that enterprise and customer-level risk assessments be updated at least every three months.p.5
4. Under Dubai Travel Rules, recipient identity verification becomes mandatory when daily aggregate transactions reach or exceed 3,500 AED.p.5
5. A December 2025 study by the UAE Financial Intelligence Unit identified fraud as the most prevalent predicate offense among filed virtual asset reports.p.6
6. In November 2025, VARA mandated licensed entities to submit board-approved remediation plans within 60 days following new federal legal updates.p.7
7. The Ministry of Finance in Vietnam received seven crypto market pilot applications by early 2026, of which five met basic documentation requirements.p.8
8. Domestic retail investors in Vietnam face fines of VND 30–50 million for trading on non-licensed platforms once the first licensed exchange opens.p.8