Virtual Assets Regulatory Authority (Dubai)
Your VARA compliance monitoring programme, built from the Rulebooks
VARA content is the first loaded into the Kompendra compendium. Each requirement is a record you can mark applicable per licence, link to your policies and controls, and test.
Status: Loaded first. The VARA Rulebooks are the first content in the compendium. TODO(Miles): confirm status at launch
What the compendium covers for VARA
- Company Rulebook
- Compliance and Risk Management Rulebook
- Technology and Information Rulebook
- Market Conduct Rulebook
- Activity rulebooks for VA Management and Investment, Broker-Dealer, Exchange and Custody services
How updates are handled
- Every requirement carries its section reference, source link, effective dates and version.
- When a rule changes, the requirement gets a new version. If you had the old version marked applicable, you get a change task to review it.
- New and changed content is reviewed by a person before it is published to the compendium.
- Drafted summaries of each change, listing your affected policies, controls and tests, are on the roadmap.
Typical monitoring tests
- A periodic review of a sample of new client files against your customer due diligence procedures.
- A check that each item on the compliance monitoring plan was performed, reviewed and evidenced on time.
- A review of a sample of transactions escalated by your monitoring tools, and how they were dispositioned.
- A check that policies due for review were reviewed and re-approved by the right people.
- A check that staff completed read-and-attest for updated policies.
Glossary
- VARA
- The Virtual Assets Regulatory Authority, which regulates virtual asset activities in and from Dubai, outside the DIFC.
- VASP
- Virtual Asset Service Provider. A firm licensed by VARA to carry out one or more VA Activities.
- VA Activity
- A regulated virtual asset activity, such as broker-dealer, custody, exchange, or management and investment services.
- Compulsory Rulebooks
- The rulebooks that apply to every VASP whatever its activities, including the Company, Compliance and Risk Management, Technology and Information, and Market Conduct rulebooks.
- MLRO
- Money Laundering Reporting Officer.
The tests above are examples of what a plan can hold. Your own tests come from the requirements you mark applicable and from your policies. Kompendra can suggest tests from the requirement text for you to accept, edit or reject.
TODO(Miles): check the glossary definitions and the list of rulebooks against the current VARA publications