“OTC” describes how a trade is arranged, not its regulatory status. A firm buying virtual assets for its own account is different from one arranging trades for clients, matching counterparties, taking custody or operating an exchange. Map the actual activity before deciding whether VARA authorisation is required in Dubai outside DIFC.

Which facts matter?

Record who owns the assets before and after each trade, who sets prices, who bears settlement risk, whether the firm advertises to clients, whether it handles client money or keys, and whether it receives a commission. One business can perform more than one regulated activity.

VARA’s activity rulebooks distinguish licensed virtual-asset services. Its own-account investment rule includes registration when specified own-account activity reaches USD 250 million equivalent in a rolling 30-day period. Staying below that threshold does not by itself exempt broker-dealer, exchange, custody or other client-facing services.

What about a Dubai court case sometimes cited in OTC guides?

Commentary about Dubai Court of Cassation case 452/2024 exists, but the official judgment has not been verified for this guide. We therefore do not treat an account of that case as authority for a general OTC exemption or penalty rule. Obtain the judgment and assess its facts and holding before relying on it.

What should you do before trading?

Prepare a transaction-flow diagram, entity and client map, contract set, settlement process, custody description and expected volumes. Ask whether each step happens for the firm’s own account or for another person. Review AML/CFT, sanctions and banking requirements separately from the licence question. A bank’s onboarding decision is institution-specific and is not itself a legal permission.

Sources and notes

Updated 24 September 2026. General information, not a licensing opinion. No unverified court holding is relied upon.