Compliance Handbook

How to Open a Bank Account for Your VASP

Banking Access Strategy: Emirates NBD, Mashreq, Documentation, Timeline, and Ongoing Requirements

Published February 16, 2026 · UAE Tokenization Regulations Editorial Team

The banking landscape for UAE VASPs continues to evolve as regulatory clarity increases institutional confidence. The CBUAE Virtual Asset Guidance issued in late 2025 provides licensed financial institutions with standardized due diligence frameworks for VASP relationships, reducing the ambiguity that previously made banks reluctant to engage with virtual asset businesses.

This implementation guide provides step-by-step instructions for practitioners navigating this aspect of UAE virtual asset compliance. Designed for compliance officers, in-house legal teams, VASP founders, and regulatory consultants, the guide translates regulatory requirements into actionable operational procedures that can be implemented within existing compliance workflows. All regulatory citations reference official publications from the relevant UAE regulatory authorities, with guidance current as of February 2026.

Regulatory Framework Context

The UAE's virtual asset regulatory architecture encompasses five distinct authorities: VARA governing Dubai mainland and free zones (excluding DIFC), ADGM FSRA operating as an independent international financial center in Abu Dhabi, DIFC DFSA functioning as a separate common-law jurisdiction within Dubai, the SCA/CMA providing federal-level securities oversight, and the CBUAE retaining exclusive authority over payment tokens and AED-denominated stablecoins. Each regulator maintains distinct requirements, and practitioners must identify the applicable regulatory authority before implementing compliance measures. All guidance in this handbook reflects the regulatory framework as of February 2026, incorporating VARA Rulebook 2.0 (effective June 2025), ADGM FRT framework (effective January 2026), and DIFC Consultation Paper 168 proposals.

Implementation Considerations

Compliance implementation in the UAE requires navigating jurisdictional complexity that goes beyond simply meeting a single regulator's requirements. Multi-jurisdictional operators — holding licenses in both VARA and ADGM, for example — must maintain parallel compliance programs tailored to each regulator's specific rulebook requirements. The August 2025 CMA-VARA mutual recognition agreement is reducing some of this burden through shared frameworks, but operational compliance teams should continue to treat each jurisdiction's requirements independently until formal harmonization is confirmed. Technology compliance, AML/CFT programs, and governance structures must be documented separately for each licensing jurisdiction, even where underlying systems are shared across entities.

Practical Recommendations

Engage specialist UAE virtual asset legal counsel before committing to a regulatory pathway — the choice of jurisdiction has cascading implications for licensing costs, capital requirements, operational structure, and client access. Begin banking engagement immediately upon receiving initial VARA or ADGM approval, as account opening typically takes 3-6 months and can delay operational launch. Build OECD CARF-compliant data collection infrastructure from inception rather than retrofitting existing systems. Invest in technology compliance from day one — the cost of implementing TGRAF, penetration testing, and custody standards increases significantly when bolted onto existing infrastructure versus being designed into the platform architecture from the ground up. For the latest regulatory guidance, consult official sources: VARA Regulations, ADGM Digital Assets, and DFSA. This guide is for informational purposes only and does not constitute legal, financial, or regulatory advice.

Documentation Package

Prepare a comprehensive due diligence package before approaching banks: detailed business model description explaining how your VASP generates revenue and processes transactions, transaction flow diagrams showing fiat and virtual asset movement, projected monthly transaction volumes and values for the first 12 months, source of funds documentation for initial capital and ongoing operations, complete AML/CFT policies and procedures manual, copies of all VARA or ADGM regulatory correspondence, Fit and Proper declarations for all directors and beneficial owners, audited financial statements (or management accounts for newly formed entities), and proof of regulatory licensing status (ATI or full VASP license). Present documentation professionally — bank compliance teams assess the quality of your compliance materials as an indicator of operational maturity.

Stablecoin Settlement Alternatives

Circle USDC (CBUAE-authorized) and Tether USDT (ADGM-recognized across 12+ blockchains) provide alternatives to traditional banking for certain settlement functions. Dubai's Cashless Strategy targeting 90% cashless transactions by 2026 is expanding crypto payment acceptance infrastructure. Stablecoin settlement reduces but does not eliminate banking dependency — fiat on/off ramps, payroll, regulatory fee payments, and tax obligations still require traditional banking access for most VASPs.

Relationship Management Strategy

Banking relationships for VASPs require active management beyond the initial account opening. Assign a dedicated relationship manager responsible for quarterly compliance reporting to bank partners, advance notification of material business changes including new products and markets, responsive communication with bank compliance teams during periodic reviews, and coordination during annual account assessments. Build redundancy by maintaining relationships with multiple banking partners — account closure by a single bank should not create an existential threat to operations. Document all banking communications and compliance submissions to demonstrate institutional-grade relationship management during VARA inspections.

Account Maintenance Best Practices

Maintaining banking relationships requires continuous compliance investment. Submit quarterly reports to banking partners covering transaction volumes, AML program updates, regulatory correspondence, and any material business changes. Respond to bank compliance inquiries within 24-48 hours — delayed responses create friction that can escalate to account review proceedings. Avoid transaction patterns that trigger bank monitoring alerts: unusual spikes in transaction volume or value, frequent transfers to high-risk jurisdictions, or unexplained changes in transaction patterns should be accompanied by proactive explanations to your banking compliance contact. Building institutional trust through consistent, transparent communication protects the banking access that remains essential for operational viability.

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