Victoria Wells
Principal & Co-Founder
Victoria Wells is the Principal and Co-Founder of Ape Law, a UAE-headquartered Web3 law firm specialising in digital asset regulation, VASP licensing, and tokenization across 8+ jurisdictions.
Before founding Ape Law, she was Chief Legal Officer at Illuvium, one of the largest GameFi projects globally, where she led a first-of-its-kind VARA licence application covering exchange, broker-dealer, custody and asset-management categories, and made Illuvium the first DAO to secure banking in the UAE. She earlier founded Alt Law in Australia and has long pioneered Web3 and digital-asset legal structures, including the first-ever VC fund manager licence in ADGM permitting investment into virtual assets, SAFTs, SAFEs and Token Warrants.
Vice President, LawFi DAO · Member of LexDAO and the MENA Fintech Association
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At a glance
Track record
6+
Years in Web3 law
$500M+
Token raises structured
8+
Jurisdictions
25+
Jurisdictional analyses
12+
Crisis situations resolved
Former CLO
at Illuvium
Notable engagements
Selected work
Digital asset licensing
CHALLENGE
No licensing precedent existed for GameFi or DAO-native businesses in the UAE.
THE WIN
The first-ever ADGM VC fund-manager licence, plus the first VARA filings built specifically for GameFi.
Obtained the first-ever VC fund manager licence in ADGM permitting investment into virtual assets, SAFTs, SAFEs and Token Warrants
Prepared and filed comprehensive VARA applications for Illuvium — Exchange, Broker-Dealer, VA Management and Investment licences — the first VARA application tailored specifically for GameFi
Developed regulatory strategy for centralised exchanges seeking licensed operations in the UAE, navigating VARA, ADGM and DIFC requirements simultaneously
Made Illuvium the first DAO to secure banking services in the UAE region
International advisory
CHALLENGE
Clients expanding across fragmented, sometimes conflicting regimes in Singapore, the UAE and the EU.
THE WIN
Market-entry strategies that keep jurisdictional options open and cut regulatory friction.
Created a global market entry strategy for a tokenized securities platform across Singapore, UAE and EU jurisdictions
Advised a Layer 1 protocol on business-model structure to minimise regulatory friction while maximising jurisdictional optionality
Provided strategic guidance for a DeFi investment DAO on global VASP frameworks and risk-management strategies
Corporate structuring & token design
CHALLENGE
Token and corporate models that have to stay flexible without tripping the regulatory perimeter.
THE WIN
Dual-track structures and clean token launches, from ERC-404 to fractional real-world assets.
Implemented dynamic corporate structuring for a GameFi DAO, maintaining both regulated and unregulated pathway options
Led end-to-end legal support for an ERC-404 token launch and listing
Advised a fractional real-world asset issuer on token design and global audience marketing strategy
Crisis & emergency response
CHALLENGE
Live exposure — stalling launches, founder disputes, projects at acute regulatory risk.
THE WIN
Emergency restructuring in under 24 hours and founder disputes resolved across jurisdictions.
Executed emergency restructuring in under 24 hours for projects exposed to high regulatory risk
Provided critical on-site support during token launches, managing emergency situations in real time
Successfully resolved founder disputes across multiple jurisdictions with mutually held assets
Practice areas
What Victoria covers
VARA licensing
Full VASP licence applications across all seven activity categories
ADGM crypto licensing
FSRA-regulated digital asset licensing in Abu Dhabi
DIFC licensing
DFSA-regulated fintech and digital asset licensing
RWA tokenization
Tokenized real estate, securities and commodities under UAE frameworks
Token launches & structuring
ICO/IDO/ITO legal frameworks, SAFT/SAFE agreements, tokenomics
DAO structuring
Legal entity structuring for DAOs, governance frameworks, DIFC foundations
Fund creation & licensing
QIF/PIF setup, fund manager licensing, SPV structuring
Fundraising & M&A
SAFT/SAFE agreements, investor negotiations, strategic acquisitions
GC / CLO-as-a-Service
Embedded legal counsel for Web3 teams
Crisis & dispute resolution
Exploit response, regulatory investigations, founder disputes, emergency restructuring
Cayman VASP registration
Offshore VASP structuring
EU MiCA strategy
European market entry for digital asset businesses
What clients say
In their words
Danny Wilson
Chief Financial Officer, Illuvium & Illuvium Labs
“Victoria has been instrumental in shaping our global legal and regulatory strategy. At a time of intense uncertainty across GameFi and DeFi, she brought rare clarity, foresight, and relentless execution. Her work culminated in a first-of-its-kind VARA license application tailored specifically for GameFi, covering exchange, broker-dealer, custody, and asset management categories. Her dual-track legal strategy — balancing regulated applications with offshore structures — has become the gold standard for projects needing agility without sacrificing credibility. One of her most notable achievements was successfully banking our DAO in the UAE, making Illuvium the first DAO to secure such access in the region.”
Caroline Bowler
Chief Executive Officer, BTC Markets
“Victoria and her team bring an exceptional level of depth and clarity to what is often a complex and fragmented regulatory environment. Her detailed understanding of the various regulatory frameworks for digital asset businesses in the UAE — from VARA to ADGM to DIFC — is truly par excellence. Her ability to parse regulatory intent, anticipate implementation risks, and translate that into operational impact is unmatched in our experience. More than a legal advisor, Victoria has become a trusted extension of our management team. She doesn't wait to be instructed — she consistently anticipates our needs and delivers insight ahead of time. She has also been instrumental in engineering high-value introductions with regulators and ecosystem partners critical to our market entry strategy.”
Ala Aljayyusi
Managing Director, CBIX Tech Labs & CBIX Investments
“Victoria has played an instrumental role in establishing and licensing both CBIX Tech Labs and CBIX Investments, navigating complex regulatory frameworks with clarity, precision, and exceptional commercial acumen. Her ability to not only advise, but to anticipate and architect the legal foundations of our innovation ecosystem, has been critical to our growth trajectory. As we continue to incubate and launch emerging fintech solutions, Victoria has been a steadfast legal partner — pragmatic, strategic, and deeply attuned to the demands of regulated innovation. Her seamless integration into our executive and operational teams sets her apart from traditional advisors. She does not merely support our business — she helps shape it.”
Troy Sadler
Chief Executive Officer, ArtworksX
“Ape Law was our go-to for best-in-field legal advice and tokenomics for our fine art asset token launch. Their expertise across issue and launch jurisdictions, web-native perspective, and regulatory network have supported us in taking our venture from concept to reality. What sets Victoria and her team apart is their deep understanding of both the technical and legal dimensions of tokenization. While other firms struggle with the intersection of art, tokens, and compliance, Ape Law navigated these complexities with confidence. They are truly partners in our artistic revolution, enabling traditional art markets to embrace Web3 innovation.”
Victoria's take
“In the UAE, the biggest regulatory risk isn't non-compliance, it's building on the wrong foundation.”
Founders who treat licensing as a checkbox exercise end up restructuring six months later at ten times the cost. We work backwards from where you want to be in two years and engineer the legal architecture to get you there.
Victoria Wells
Principal & Co-Founder, Ape Law
FAQ
Frequently asked questions
Does Victoria Wells advise on VARA licensing?
Yes. Victoria leads all VARA licensing work at Ape Law, including applications across all seven activity categories: Exchange, Broker-Dealer, Custody, VA Management, Lending & Borrowing, VA Transfer, and VA Issuance. She prepared and filed comprehensive VARA applications for Illuvium — one of the largest GameFi projects globally — covering Exchange, Broker-Dealer, VA Management and Investment licenses. Victoria has also developed regulatory strategy for centralized exchanges seeking licensed operations across VARA, ADGM, and DIFC. See our VARA License Application service for details.
What is Victoria Wells's background in crypto law?
Victoria has over 6 years of experience pioneering Web3 and digital asset legal structures. She served as Chief Legal Officer at Illuvium, founded Alt Law in Australia before co-founding Ape Law in the UAE, and is Vice President of LawFi DAO and a member of LexDAO and the MENA Fintech Association. Under her leadership, Ape Law has structured over $500M in compliant token raises and obtained the first-ever VC fund manager license in ADGM permitting investment into virtual assets. She covers 8+ jurisdictions including VARA, ADGM, DIFC, Cayman, Singapore, and EU MiCA frameworks.
What makes Ape Law different from other crypto law firms in Dubai?
Ape Law is the only Web3 law firm in the UAE with an in-house CTO. Co-founder Stephan Roberto — a Bitcoin miner and investor since 2012, DeFi developer (including UniSwap), and computer engineer — works alongside Victoria to deliver both legal and technical expertise under one roof. This means Ape Law can review smart contracts, assess tokenomics, and evaluate technical architecture alongside the legal structuring — something traditional law firms cannot do. The firm also offers GC-as-a-service and CLO-as-a-service, embedding directly with client teams rather than just advising from the outside.
Has Victoria Wells worked with major Web3 companies?
Yes. Victoria served as Chief Legal Officer at Illuvium, where she led a first-of-its-kind VARA license application tailored for GameFi. She has also advised BTC Markets (one of Australia's largest crypto exchanges), CBIX Tech Labs and CBIX Investments (establishing and licensing both entities), and ArtworksX (fine art asset tokenization). Ape Law's client roster includes top-tier cryptocurrency exchanges, institutional banking partners, prominent DAOs, and leading GameFi platforms.
Does Victoria Wells advise on tokenization and RWA projects?
Yes. Victoria has led tokenization engagements across real estate, securities, commodities, and alternative assets including fine art. She advised a fractional real-world asset issuer on token design and global audience marketing strategy, and her team has created global market entry strategies for tokenized securities platforms across Singapore, UAE, and EU jurisdictions. Ape Law covers tokenization under VARA, ADGM, and DIFC frameworks. See our RWA Tokenization service for details.
Can Ape Law handle crisis situations and emergency legal matters?
Yes. Ape Law has resolved 12+ crisis situations, including executing emergency corporate restructuring in under 24 hours for projects exposed to high regulatory risk. Victoria has provided critical on-site support during token launches, managing emergency situations in real-time, and has successfully resolved founder disputes across multiple jurisdictions involving mutually held assets. See our guide on Crypto Dispute Resolution in the UAE.
Does Ape Law offer ongoing legal support or just project-based work?
Both. Ape Law offers GC-as-a-service (General Counsel as a Service) and CLO-as-a-service (Chief Legal Officer as a Service), embedding directly with client teams for ongoing legal stewardship across digital assets, AI implementations, and frontier technology initiatives. This is in addition to project-based licensing, structuring, and advisory work. The approach delivers partner-level expertise without premium Big Law rates.
How many jurisdictions does Victoria Wells cover?
Victoria has direct expertise across 8+ key jurisdictions and has completed 25+ jurisdictional analyses for optimal client operations. Primary jurisdictions include UAE (VARA, ADGM, DIFC), Cayman Islands, Singapore, EU (MiCA), BVI, and Australia. She has created global market entry strategies addressing regulatory frameworks across multiple regions simultaneously. See our EU vs UAE and Singapore vs Cayman comparisons.
How do I contact Victoria Wells?
You can request to speak directly to Victoria through the contact form.
What does an engagement with Ape Law look like?
Ape Law follows a five-stage process: (1) Listen — understanding your vision, objectives, and constraints; (2) Analyze — identifying regulatory challenges and strategic opportunities; (3) Strategy — developing a tailored legal roadmap aligned with your goals; (4) Execute — implementing the plan with practical, hands-on support; (5) Iterate — adapting as regulations evolve and your project grows.
Published legal analysis
Writing & guides
The Real Cost of Getting ADGM Licensing Wrong
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EU vs UAE Crypto Regulations: Key Differences
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How to Structure a DAO with UAE Operations
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Tokenized Real Estate Under VARA: Compliance Checklist
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Stablecoin License Costs in UAE: VARA, ADGM & CBUAE
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ADGM vs DIFC vs VARA: Best Jurisdiction for Tokenizing Assets
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What to Do When a Crypto Co-Founder Dispute Arises in UAE
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VARA License Cost Guide
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UAE Crypto License Guide
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Work with Victoria
Build on the right foundation
Speak directly with Victoria about your licensing, structuring, fundraising or crisis matter.
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