Dubai’s Virtual Assets Regulatory Authority (VARA) issued a reserve asset audit circular on Oct. 6, setting out the minimum requirements for independent audits of virtual asset service providers, or VASPs. Under the circular, a VASP must maintain reserves equal to at least 100% of customer liabilities throughout the full review period. Those reserves must be held in the same virtual assets on a 1:1 basis, with daily reconciliations required. The audit scope must cover hot wallets, warm wallets, cold wallets, third-party wallet infrastructure, and assets held with third-party custodians. Auditors are also required to verify whether customer assets are properly segregated, whether wallet control remains with the relevant party, and whether any assets have been used for rehypothecation, lending, or other purposes. The notice lays out a clear baseline for how reserve assets should be examined during independent reviews of VASPs operating under VARA’s oversight.
Dubai’s Virtual Assets Regulatory Authority (VARA) issued a reserve asset audit circular on Oct. 6, defining the minimum requirements for independent audits of virtual asset service providers (VASPs).
Under the circular, VASPs must maintain reserves equal to no less than 100% of customer liabilities throughout the entire review period. Those reserves must be held in the same virtual assets on a 1:1 basis, and reconciled daily.
The audit scope must cover hot wallets, warm wallets, cold wallets, third-party wallet infrastructure, and assets held with third-party custodians. Auditors must also check the segregation of customer assets, wallet control, and whether any assets have been subject to rehypothecation, lending, or other forms of use.
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