Article (8) /
Chapter
Four Part
Three of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine.
Suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine.
Cancellation of
the licence, or
one of these
two penalties.
52 The partners and
members of the Board of
Directors of VASP, its
director, or its Board of
Directors, and its
employees, when
executing any trading
orders for themselves or
for the account of their
spouses, ascendants or
branches up to the second
Paragraph
(1) / Article
(9) /
Chapter
Four/ Part
Three of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine.
(400,000)
dirhams fine.
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degree, or for the account
of any of these spouses or
minor children, to comply
with the stipulated
obligations.
53 VASP non-compliance to
comply with the
obligations concerning the
execution of trading
orders for partners,
members of the Board of
Directors, the Director or
the Board of Directors and
its employees.
Paragraph
(2) / Article
(9) /
Chapter
Four / Part
Three of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
54 Employees of VASP
trading in certain VA if the
Service Provider, in
accordance with its
licence, provides financial
advice relating to the VA or
its Source or on VA related
thereto or its Source
before it is published. This
is made available to all
Service Provider
customers.
Paragraph
(4) / Article
(9) /
Chapter
Four/ Part
Four of the
Rulebook.
(100,000)
dirhams fine.
(200,000)
dirhams fine.
(400,000)
dirhams fine.
(800,000)
dirhams fine.
55 Non-compliance to
include the data contained
in Appendices No. (1), (2),
(3) and (6) of Part Three of
the Rulebook.
Appendices
No. (1), (2),
(3) and (6)
of Part
Three of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
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56 VASP non-compliance to
the requirements under
the “Guidelines for
Financial Institutions
Adopting Enabling
Technologies”, which was
issued by the Central Bank
of the UAE (CBUAE),
together with the
Securities and
Commodities Authority
(SCA), the Dubai Financial
Services Authority (DFSA)
of the Dubai International
Financial Centre and the
Financial Services
Regulatory Authority
(FSRA) of Abu Dhabi
Global Market.
Paragraph
One /
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
(100,000)
dirhams fine.
(200,000)
dirhams fine.
(400,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(800,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
57 VASP non-compliance
providing the VA Wallet
Service to provide
procedures describing the
process of creating and
managing VA Wallets and
the controls related
thereto.
Clause (1)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
58 VASP non-compliance
providing the VA Wallet
Service to provide
procedures describing the
process of private key
creation, management,
and controls.
Clause (2)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
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these two
penalties.
59 VASP non-compliance –
which provides the VA
Wallet service – to provide
the necessary systems and
controls to mitigate the
risks of misuse of VA.
Clause (3)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
60 VASP that provides the VA
Wallet Service does not
have a security plan
describing the
arrangements, procedures
and security measures
used to securely store and
transmit data.
Clause (4)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
61 VASP – which provides
the VA Wallet Service –
does not have a risk
management plan that
includes a detailed
analysis of likely risks with
both high and low impact,
as well as mitigation
strategies.
Clause (5) /
Paragraph
Two /
Appendix
No. (7)
Wallet VA/
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence or
one of these
two penalties.
62 VASP non-compliance
providing the (VA Wallet)
service to:
1. Once they have been
licensed by SCA, the Safe
Guarding processes and
Clause (6)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
(400,000)
dirhams fine
and
cancellation of
the licence or
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systems shall be tested on
a scheduled recurrent
basis, with evidence of
such tests and findings
thereof being
appropriately
documented. The
schedule for system
testing shall be included in
its protocols to be
submitted to SCA upon
request.
2. Schedule shall take into
consideration procedural
risks as well as high-
impact financial risks.
3. Systems testing shall be
undertaken in line with
the industry best
standards and practices.
Part Three
of the
Rulebook.
exceeding one
year, or one of
these two
penalties.
one of these
two penalties.
63 VASP non-compliance
providing the (VA Wallet)
service to:
1. Disclosing the proposed
automation of its
functions in the
procedures manual
submitted at the time of
submitting the
application, as well as
failing to provide
appropriate justifications
and justifications.
2. Update the Operational
Risk Management
Programme (ORMP) in a
timely manner to develop
scenarios to be followed in
Clause (7)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
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the event of automation
non-compliance.
64 VASP non-compliance
providing the (VA Wallet)
service to:
1. As stated in the
Rulebook concerning the
general requirements
imposed by SCA and
related to outsourcing
activities.
2. The requirements
related to the VA Wallet in
accordance with the
details contained in Clause
(8) / Paragraph Two of
Appendix No. (7) VA
Wallet of Part Three of the
Rulebook.
Clause (8)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
65 VASP non-compliance
providing the (VA Wallet)
service to:
1. Implement processes
and procedures
concerning decision-
making and access to
sensitive information and
security systems.
2. Maintain clear audit
records and review of the
decision-making process,
and no staff with decision-
making responsibilities
and who have adequate
expertise, particularly
from a technological
standpoint, may make
such decisions.
Clause (9)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
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3. Apply measures should
be implemented to restrict
access to critical and/or
sensitive data to key
personnel only.
66 VASP non-compliance
that provides the VA
Wallet Service to put in
place policies and
measures aimed at
ensuring that private keys
are not compromised.
Clause (10)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
67 VASP non-compliance
with clear policies and
procedures that detail
procedures for recovery in
the event that a customer
loses access credentials.
Clause (11)
/ Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
68 VASP non-compliance
providing the (VA Wallet)
service to:
1. Establish policies and
procedures, consistent
with the AML Rules
applicable thereto, to
identify the source of
funds and to ensure their
compliance with SCA AML
Guidelines.
2. Authorised Persons
shall perform due
Clause (12)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
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diligence on their
customers before opening
an account so that wallet
addresses can be
identified as belonging to
a specific user.
69 VASP non-compliance
providing the VA Wallet
service to:
1. Implement measures
and procedures that are in
line with best practices in
the network security
industry.
2. Updates and patches to
all systems, particularly
security systems, should
be performed as soon as
safely feasible after such
updates.
3. Implement security
policies for IT
infrastructure that
specifically describe the
robustness of multi-
layered security protection
and how “weak points”
have been addressed.
4. IT infrastructure is
robust enough to handle a
range of scenarios without
incurring significant losses
to customers.
5. Develop information
security policies and
procedures for all
employees.
Clause (13)
/ Paragraph
Two /
Appendix
No. (7)
Wallet
Virtual /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
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6. The strong encryption of
data, both at rest and in
transit, should be included
in the security policy.
7. Record and document
all security incidents and
breaches in its finest
details as soon as
practically possible
8. Use open source
software in accordance
with clear, transparent and
well-documented rules
and procedures.
9. All internal or external
APIs shall be secured by
strict access management
procedures and systems,
including encryption of
the information.
10. All access
management and
credential changes (for
employees, third-party
Service Providers and
customers) shall be
governed and monitored
by strict and well-
documented rules and
procedures.
70 VASP non-compliance
providing the VA Wallet
service to:
1. Demonstrate that as
part of his protocols, each
signatory will be required
to document the rationale
to approve or reject a
Clause (14)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
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transaction in relation to
VA protocols in place.
2. The applicant will also
be required to maintain a
detailed log for any
change in the chain of
access to VA.
3. Records of transaction
approval/rejection and
supporting justifications
as well as any change in
the chain of access to VA,
may also be made
available, upon request,
for review by the owner of
the VA subject to the
transaction.
of the
Rulebook.
these two
penalties.
71 VASP non-compliance
providing the VA Wallet
Service to establish a
documented system for
detecting suspicious or
fraudulent transactions
and procedures for
reviewing suspicious
transactions.
Clause (15)
Paragraph
Two/
Appendix
No. (7) VA
Wallet /
Part Three
of the
Rulebook.
Warning. (100,000)
dirhams fine.
(200,000)
dirhams fine
and suspension
from practising
the activity for a
period not
exceeding one
year, or one of
these two
penalties.
(400,000)
dirhams fine
and
cancellation of
the licence, or
one of these
two penalties.
72 VASP non-compliance to
include in its protocols the
disclosure of the source of
the valuation and the
methodology followed in
that to the Customer and
the signatory parties
before
