Virtual asset service provider / Web3 · 2026-01-10 · Anonymised case study

Indian Crypto Exchange Secures VARA Broker-Dealer + Exchange Licence

Mumbai-HQ Web3 trading platform: 180,000 users, USD 40M monthly volume, post-Section-194S 1% TDS pressure, FIU-IND enforcement risk. Choice: VARA vs Singapore MAS DPT. We recommended VARA: MAS effectively closed to retail DPT applicants by 2024; VARA permits retail activity tiered; capital adequacy predictable. DMCC over IFZA/JAFZA/ADGM for VASP-experience and bank-onboarding track record. 9-month execution: Stage 1 IDQ (sources-of-funds evidence across 2019-22 angel rounds), Stage 2 Operating Licence (1,400 pages of policies, Big-4 tech audit, ICAAP, custody segregation), MLRO appointment (ex-RBI compliance lead), AED 4.2M capital deposit at ENBD, ENBD private-banking activation. Operational retail + institutional offering.

All client details have been anonymised. Industry sector, asset perimeter, regulator interactions and structural patterns are accurate to the matter as executed. Specific figures may have been rounded or generalised to protect client confidentiality.