A banking plan has two separate parts: regulatory capital arrangements and the bank’s decision to onboard the operating business. Neither automatically resolves the other.
What does VARA require for paid-up capital?
VARA’s Company Rulebook, section VI.B.3 allows paid-up capital to be held in a trust account with a licensed UAE bank naming VARA as beneficiary, supported by a qualifying surety bond, or held in another manner specified by VARA on licensing. The former “bank or surety only” description missed that third route. Confirm what VARA specifies for the particular application.
That capital arrangement is different from the everyday operating account. A bank may apply its own onboarding and risk policy, subject to its legal duties. There is no published UAE-wide rule that all banks must open, or refuse, an operating account at a particular licensing stage.
What should the application file show?
| Question | Evidence to prepare |
|---|---|
| Who owns and controls the business? | Corporate records, shareholder chain, beneficial-owner evidence and signatory authority. |
| What does it do? | Product, customer, transaction and money-flow description consistent with the licence application. |
| Where does capital come from? | Documentary source-of-funds trail, including material crypto-to-fiat movements. |
| How are risks managed? | AML/CFT, sanctions and transaction-monitoring responsibilities where applicable. |
| What is the regulatory status? | Current licence, application status or regulator correspondence, stated accurately. |
These are practical preparation categories, not a guarantee that a bank will accept the file. Ask each institution for its current requirements and permitted account purpose.
How should you sequence banking and licensing?
Discuss the capital route with the relevant regulator while preparing the operating-account file. Avoid assuming that an in-principle approval automatically opens an account, or that a trade licence alone covers a regulated virtual-asset service. Document any bank-specific condition and keep capital and operating cash flows distinct.
For help with the evidence file, see our crypto banking strategy service. If VARA authorisation is also in scope, see VARA licence applications, or contact Ape Law about the sequence.
Sources and notes
- VARA, Company Rulebook capital provisions: trust account, surety bond and other VARA-specified manner; check the current licence conditions.
- UAE Federal Decree-Law 10/2025: federal AML context. It does not dictate every bank’s commercial onboarding decision.
Updated 24 September 2026. This is general information; banking terms and regulatory conditions are institution- and activity-specific.
Stephan Roberto
