Full Market Product Regulations
The Full Market Product (FMP) Regulations are VARA’s comprehensive regulatory framework governing virtual asset activities in Dubai. Published as part of the Virtual Assets and Related Activities Regulations 2023, the FMP Regulations establish detailed requirements for licensed VASPs, covering governance, operations, compliance, technology, customer protection, and market conduct.
Regulatory Context
The FMP Regulations represent the second stage of VARA’s regulatory development. VARA initially operated under a provisional regulatory framework before publishing the full market product regulations that established the complete regulatory architecture. The FMP Regulations are published as VARA rulebooks accessible at rulebooks.vara.ae.
Key Components
Activity-Specific Rules: The FMP Regulations contain activity-specific requirements for each of VARA’s seven licensed activity categories: advisory, broker-dealer, custody, exchange, lending/borrowing, management/investment, and transfer/settlement.
Company Rules: Governance, organizational structure, and corporate management requirements applicable to all licensed VASPs.
Compliance and Risk Management Rules: Requirements for compliance function, risk management, internal audit, and regulatory reporting. These rules underpin the compliance programs described in our AML program design guide.
Technology and Information Rules: Requirements for technology infrastructure, cybersecurity, data protection, and operational resilience.
Marketing Regulations: Rules governing how licensed VASPs may advertise and market their services. Breaches of the Marketing Regulations triggered enforcement against The Open Network Foundation in July 2025.
Client Money and Asset Rules: Requirements for segregation and protection of client assets, particularly relevant for custody and exchange services.
Licensing Connection
The FMP Regulations are central to VARA’s two-step licensing process. Step 2 of the application — the Full Market Product application — specifically assesses the applicant’s readiness to comply with the FMP Regulations. Applicants must demonstrate that their operations, governance, compliance programs, and technology infrastructure meet FMP standards.
Enforcement Significance
Non-compliance with the FMP Regulations after licensing triggers VARA’s enforcement function. The Morpheus Software (Fuze) case involved regulatory breaches that included failures against FMP Regulation requirements for AML programme controls, governance, and internal systems.
VARA Circulars Supplementing the FMP Regulations
VARA issues circulars that supplement and clarify the FMP Regulations. These circulars establish binding requirements that must be read alongside the FMP framework. Key circulars issued through early 2026 include:
March 2026 AML/CFT/CPF Circular: Establishes detailed requirements for anti-money laundering, counter-terrorist financing, and counter-proliferation financing programs. This circular operationalizes the AML-related provisions of the FMP Regulations and aligns VARA’s requirements with UAE Federal Decree-Law No. 20 of 2018.
February 2026 Travel Rule Circular: Implements the UAE Virtual Assets Travel Rule requirements for VARA-licensed VASPs, specifying originator and beneficiary information collection, transmission, and verification obligations.
January 2026 FATF High-Risk Jurisdictions Circular: Establishes requirements for managing exposure to FATF high-risk jurisdictions, including enhanced screening, enhanced due diligence, and countermeasures.
January 2026 Qualified Investors Circular: Defines criteria for qualified investor classification, which affects marketing restrictions and product access rules.
The continuous issuance of circulars means that compliance officers must maintain active monitoring of VARA communications to ensure their compliance programs remain current. See our compliance calendar for regulatory update tracking.
Relationship to Federal Framework
The FMP Regulations operate within the overarching federal framework established by Cabinet Decision No. 111 of 2022, which designated the SCA and VARA as primary virtual asset regulators. While VARA’s FMP Regulations govern the operational requirements for licensed VASPs in Dubai, the federal AML/CFT framework under Federal Decree-Law No. 20 of 2018 provides the baseline anti-money laundering requirements that apply across all UAE jurisdictions including Dubai.
VARA’s March 2026 AML/CFT/CPF circular explicitly bridges this relationship, requiring licensed VASPs to implement the UAE federal AML/CFT requirements as operationalized through VARA-specific guidance. This layered approach — federal law providing the legislative basis, with VARA’s FMP Regulations and circulars providing operational detail — creates a comprehensive compliance architecture that VASPs must navigate.
The FMP Regulations also interact with CBUAE payment token regulations for VASPs dealing in payment tokens, creating potential multi-authority compliance obligations for firms whose activities span both virtual asset and payment token categories.
Practitioner Implications
Compliance officers must maintain current knowledge of the FMP Regulations and any amendments. The FMP framework represents the most comprehensive standalone virtual asset regulatory regime in the UAE, distinguishing VARA’s approach from ADGM-FSRA’s integrated approach and DFSA’s securities-focused approach.
Practitioners should note several practical aspects of working within the FMP framework:
- The FMP Regulations are published as VARA rulebooks accessible at rulebooks.vara.ae, providing the authoritative text
- Activity-specific requirements must be cross-referenced against the entity’s specific licensed activity categories
- Technology and information governance requirements reflect VARA’s expectation that VASPs maintain robust technical infrastructure, including blockchain analytics (Chainalysis, Elliptic, Crystal Blockchain) and KYC platforms
- Advisory firms (Deloitte Middle East, PwC Middle East) can provide interpretive guidance on specific FMP requirements
For the full cost of compliance under the FMP framework, see the total cost of compliance model and the cost comparison dashboard.
Related Terms
- Virtual Asset Service Provider
- Cease-and-Desist Order
- Anti-Money Laundering
- Financial Services and Markets Regulations
For regulatory context, visit UAE Tokenization Regulations and Dubai Tokenisation.