Where a licence is involved, certain titles need sign-off before anyone can hold them, and timelines move accordingly.
Every statement carries its source in the margin.
Twelve weeks
A controlled function is a role the regulator must approve before anyone can hold it. In ADGM, when one falls vacant, temporary cover is allowed in exceptional circumstances, on written notice to the FSRA before that person starts, and ordinarily for no longer than twelve weeks in any consecutive twelve months. Licensed Directors and Licensed Partners may not be covered temporarily at all.
The clock starts on the resignation letter.
What the rulebooks say about people
A virtual asset firm appoints two Responsible Individuals, senior people who answer for the firm's compliance with all its legal and regulatory obligations. Both are full-time employees. Both are resident in the UAE or hold a UAE passport. Both are approved by VARA during the licensing process.
You are recruiting them into a firm that has no licence yet.
The Compliance Officer holds at least five years in a compliance function, works full-time, and reports directly to the Board.
Four appointments must be held at all times: Senior Executive Officer, Finance Officer, Compliance Officer, Money Laundering Reporting Officer. Three of the four must be resident in the UAE, the Finance Officer excepted. Credit rating agencies and venture capital fund managers are carved out of parts of this.
The FSRA will consider an outsourced Compliance Officer serving several firms, case by case, provided the firm can demonstrate the hours that person gives it and those hours rise as the business grows.
Under VARA, the Compliance Officer is a full-time employee of the firm.
The same title, and two different jobs. Under the FSRA it can be shared across several firms. Under VARA it is a full-time hire.
For a licensed payment service provider, the chief executive and their deputies must be individuals rather than corporate appointees, and ordinarily resident in the UAE. The rest of the management team is based here unless the Central Bank allows otherwise. Requirements sit regulation by regulation, so what binds an exchange house does not necessarily bind a payments company.
Where the firm is incorporated decides who you must hire.
The arithmetic is public
VARA's public register lists more than fifty licensed virtual asset service providers.
Each entry on that register carries the VARA appointments above: two Responsible Individuals, a Compliance Officer, an MLRO.
The people who clear these tests are countable.
An accepted offer is not a filled role
The DFSA may interview the individual as part of assessing their knowledge, skills and fitness for the role. So may the FSRA. Under the Central Bank's exchange business standards, the regulator may interview a proposed Manager in Charge, and where it declines one, a replacement must be proposed within the stated timeline or within 180 calendar days where none is given.
A search that produces one viable candidate has produced none.
The accountability is personal
In 2024, the DFSA finalised eight enforcement cases. The fines on individuals came to USD 1.3 million. The fines on firms came to USD 1.2 million. Three individuals were restricted and prohibited from operating in the DIFC.
The people capable of holding these roles read those notices.
What the rulebooks say about experience
VARA's Company Rulebook asks a firm to consider whether the substance of a person's experience is directly relevant or crucial to the activities that person will carry out. It expressly contemplates experience drawn from other industries and other jurisdictions.
That test cannot be run on a CV.
Where ValCera sits in this
ValCera is a boutique executive search firm in Dubai, working on senior and control-function mandates across regulated Fintech, Digital Assets, and AI, in the GCC and internationally.
The appointments are local. The pool is not. Part of the search is finding the person in London or Singapore who clears these tests and will make the move.
ValCera does not advise on licensing and is not a compliance consultancy. The work is finding and evaluating the people who hold these roles.
That work was learned inside regulated businesses: at Tamara, under SAMA in Saudi Arabia and the Central Bank of the UAE for its business here, and at NymCard, under the Central Bank of the UAE.
What this page is not
This page carries no regulatory advice.
Every statement above comes from a regulator's own rulebook or published record. Where a rule was ambiguous, or where the source could not be confirmed directly, the point was left out rather than filled in. Several were.
The rules themselves are a matter for a licensed legal professional.
Verified as at 18 August 2026, against the versions then in force: VARA Company Rulebook and Compliance and Risk Management Rulebook effective 19 June 2025; DFSA General Module as amended with effect from 1 July 2026; CBUAE Retail Payment Services and Card Schemes Regulation C 15/2021.
These rules move. The UAE replaced the Securities and Commodities Authority with the Capital Market Authority on 1 January 2026. This page is re-checked every six months, and the date above changes when it is.