Pin and benchmark
Pin one jurisdiction. Line up to five rivals against it. Deltas show where each peer is better or worse.
Sign in to watch these jurisdictions for changes.
| Dimension |
Pinned 🇦🇪 United Arab Emirates (Dubai - VARA) partly open Verified 2026-08-15
|
🇺🇸 United States
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | VARA VASP licence under the Virtual Assets and Related Activities Regulations 2023 - licensed PER ACTIVITY (Advisory, Broker-Dealer, Custody, Exchange, Lending & Borrowing, Management & Investment, Transfer & Settlement, plus VA Issuance). A DET/free-zone commercial licence is also required. | No single federal crypto licence. Fragmented dual-layer regime: (a) State-level Money Transmitter Licence (MTL), required in 49 states (all except Montana) plus DC, applied for via NMLS (Nationwide Multistate Licensing System) under each state's money transmission statute (31 states have adopted the Money Transmission Modernization Act, MTMA, in full or part as of Feb 2026); (b) Federal FinCEN Money Services Business (MSB) registration under the Bank Secrecy Act, via FinCEN Form 107, required for any business acting as a money transmitter/administrator/exchanger of convertible virtual currency. Some states have specific regimes (e.g., NY BitLicense from NYDFS, 23 NYCRR Part 200) as an alternative/superseding requirement. |
| Regulator | VARA (Virtual Assets Regulatory Authority) - sole authority across the Emirate of Dubai except the DIFC. Parallel UAE regimes exist: ADGM/FSRA (Abu Dhabi), DFSA (DIFC), and federal SCA/Central Bank. | No single federal crypto regulator. Federally, FinCEN (US Treasury) handles MSB registration and BSA/AML oversight. At the state level, each state's banking/financial-services department (e.g., NYDFS in New York, DFPI in California) issues and supervises money transmitter licences via NMLS. The SEC and CFTC separately assert jurisdiction over certain crypto activities (securities/commodities), the allocation of that jurisdiction is the subject of the pending CLARITY Act. |
| Capital requirement | United Arab Emirates (Dubai - VARA) capital requirement is included in the £349 pass. | United States capital requirement is included in the £349 pass. |
| Timeline to authorisation | United Arab Emirates (Dubai - VARA) timeline to authorisation is included in the £349 pass. | United States timeline to authorisation is included in the £349 pass. |
| Local substance | United Arab Emirates (Dubai - VARA) local substance is included in the £349 pass. | United States local substance is included in the £349 pass. |
| Application cost | United Arab Emirates (Dubai - VARA) application cost is included in the £349 pass. | United States application cost is included in the £349 pass. |
| Ongoing cost | United Arab Emirates (Dubai - VARA) ongoing cost is included in the £349 pass. | United States ongoing cost is included in the £349 pass. |
| Passporting | United Arab Emirates (Dubai - VARA) passporting is included in the £349 pass. | United States passporting is included in the £349 pass. |
| MiCA CASPs approved | United Arab Emirates (Dubai - VARA) mica casps approved is included in the £349 pass. | United States mica casps approved is included in the £349 pass. |
| Key restrictions | United Arab Emirates (Dubai - VARA) key restrictions is included in the £349 pass. | United States key restrictions is included in the £349 pass. |
| Recent changes | 'Rulebook 2.0' reissued all twelve rulebooks effective 19 Jun 2025 (mandatory Travel Rule, wind-down plans, TLPT, a new VA Issuance rulebook). VARA issued a circular implementing UAE federal anti-money laundering, counter-terrorism financing and proliferation financing requirements for VASPs (4 March 2026), an updated Travel Rule circular (24 February 2026), and an AML/CFT Business Risk Assessment Guidance (12 June 2026). VARA's rulebook site separately hosts a non-binding Guidance on the Virtual Asset Issuance Rulebook, covering two issuance pathways (Category 1: fiat- and asset-referenced tokens needing a VARA licence and reserve assets, except direct-ownership tokens; Category 2: other tokens, distributed only via VARA-licensed distributors or broker-dealers); this document carries no visible date on VARA's own rulebook page, but contemporaneous legal reporting consistently dates its publication to 9 April 2026. VARA has previously stated it penalised around 19 unlicensed firms. Legal-press reporting records VARA's 50th VASP licence (Tribe Tokenisation FZE) in early July 2026. No VARA news items have been published since 12 June 2026 as of 15 July 2026. VARA's own public register listed 52 licensed VASPs as of 1 August 2026, the most recent being Flipster FZE (exchange services, 14 July 2026); the register dates Tribe Tokenisation FZE, earlier reported by legal press as the 50th licensee, to 22 June 2026. No new VARA circular has been published since the 12 June 2026 AML/CFT Business Risk Assessment Guidance. | The GENIUS Act's 18 July 2026 deadline for federal implementing rules passed with no agency having finalised a rule: the OCC, FDIC, NCUA and Treasury (with FinCEN and OFAC) have issued proposed rules since December 2025, the Federal Reserve joined a five-agency customer identification proposal on 18 June 2026, and on 27 July 2026 the OCC sought approval for stablecoin issuer application forms (comments due 25 September 2026). The Act sets no penalty for the missed deadline; it takes effect on the earlier of 18 January 2027 or 120 days after final rules. The CLARITY Act remains stalled in the Senate: reported by the Banking Committee on 1 June 2026 with a substitute amendment, no cloture motion filed and no floor vote expected before the August recess; Senate Republicans circulated revised negotiating text on 22 July 2026. The SEC's three planned crypto rulemakings (token issuance safe harbour, broker-dealer capital and custody amendments, market structure) remained unpublished as of late July 2026. |
| Difficulty rating | United Arab Emirates (Dubai - VARA) difficulty rating is included in the £349 pass. | United States difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
One-question research
Did this page help you reach the next useful outcome?
No email is collected. An optional short note helps us understand what is missing.