Authority Decision No. 3 of 2023 · Dubai
Establishes the VARA Grievance Committee to hear grievances against VARA actions, penalties, sanctions and inspections, sets its membership, quorum and majority voting, lets it cancel or modify sanctions, and abrogates Administrative Decision No. 1/2023.
Administrative Resolution No. (03) of 2023, issued by VARA's Director General on 22 December 2023 and effective on issue, establishes the VARA Grievance Committee. It replaces Administrative Decision No. 1 of 2023 on the same subject, which Article 5 abrogates. The Committee is the body contemplated by Regulation IX.C.6 of the VARA Regulations, which allows VARA to set up a committee to hear grievances about its enforcement action, and it gives effect to the grievance procedure in Article 22 of Dubai Law No. 4 of 2022.
Under Article 2 the Committee considers and decides all grievances from parties in the virtual asset sector against actions taken, or penalties or sanctions imposed, under the Legislation, against inspections by VARA-authorised inspectors, or generally about how the Legislation is applied. Article 1 defines the Legislation widely: the Dubai VA Law, the VARA Regulations and all rules, regulations, directives and decisions VARA issues.
Article 3 fixes the membership: VARA's Managing Director and Vice Chairperson of the Executive Board as Chairperson; a member of VARA's Executive Board who is also CEO, Regulatory Policy and Governance, at DET; and the Chief Financial Officer of the Dubai World Trade Centre. Members may appoint authorised representatives and, with the Committee's prior approval, invite additional members who may vote.
Article 4 sets the procedure. Three members form a quorum; meetings may be virtual or in person and decisions may be taken in writing, including electronically; decisions are by simple majority, with a casting vote for the Chairperson. The Committee examines all submissions from the aggrieved party, meets in strict confidence, may hear VARA staff involved in the investigation for information only, and has absolute discretion to cancel or modify any decision, action or measure relating to a sanction, penalty or fine. Its decisions are summarised in a report to the VARA Executive Board.
Timing comes from the Dubai VA Law: Article 22 allows a written grievance to the Director General within 30 days of notification of the contested decision, requires it to be decided within 15 days of referral to the committee, and makes the committee's decision final. Article 4(7) of the Resolution requires the Committee to decide within that grievance period. The Resolution is in force.
Any party in the virtual asset sector affected by a VARA action, penalty, sanction or inspection under the Dubai VA Law, the VARA Regulations or VARA's rules and directives, including licensed VASPs, unlicensed Entities and individuals, together with the Committee members and VARA staff involved.
English official text in 5 articles. Open the full text or jump to a provision:
| Article 1 | Defines the Legislation as Dubai Law No. 4 of 2022, the VARA Regulations 2023 and all rules, regulations, directives or decisions VARA issues, as amended. |
| Article 2 | Forms the Committee to consider and determine grievances against actions taken, penalties or sanctions imposed, inspections by VARA-authorised inspectors, or the application of the Legislation generally. |
| Article 3 | Members are VARA's Managing Director and Executive Board Vice Chairperson (Chairperson), an Executive Board member who is CEO of Regulatory Policy and Governance at DET, and the Dubai World Trade Centre's Chief Financial Officer. |
| Article 4(1) to (6) | Quorum of three members; meetings when required, virtual or in person; decisions at meetings or in writing including electronically, by simple majority, with the Chairperson's casting vote on deadlock. |
| Article 4(7) to (9) | Decisions follow the grievance period under the Dubai VA Law; the Committee examines all submissions of the aggrieved party, meets in strict confidence and may hear VARA staff involved in the investigation. |
| Article 4(10) and (11) | The Committee has absolute discretion to cancel or modify any decision, action or measure on a sanction, penalty or fine, and reports its decisions to the VARA Executive Board. |
| Article 5 | The Resolution takes effect from its date of issue, is published on the VARA website, and abrogates Administrative Decision No. 1 of 2023 establishing the earlier Grievance Committee. |
When a client receives a VARA fine, enforcement notice or adverse inspection finding, the clock under the Dubai VA Law starts on notification: 30 days to lodge a written grievance with the Director General. We diarise that deadline the day the notice arrives, assemble the corporate record the Committee will need (licence history, Board resolutions, correspondence with VARA), and coordinate with the client's licensed advisers or lawyers who prepare the substantive submission. Because the Committee can cancel or modify a sanction outright and its decision is final, the written submission is usually the client's one real opportunity, so we make sure it is complete and filed on time, and that the client keeps the matter confidential as the VARA Regulations require. Polaris is not licensed by VARA; the grievance itself is argued by the client's advisers.
| Repeals | Administrative Decision No. 1/2023 Concerning the Establishment of the Dubai Virtual Assets Regulatory Authority [VARA] Grievance Committee |
| Cites | Dubai Virtual Assets Law (VARA) |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
Dubai Virtual Assets Law (VARA)
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