Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
Bybit is registered with VARA (Virtual Assets Regulatory Authority, Dubai) + ADGM FSRA (Abu Dhabi) + CBUAE (Central Bank) in United Arab Emirates. That means we have a direct regulatory path to resolve your freeze. Swiss legal team with VARA expertise. 90%+ success rate.
Bybit received VARA MVP license (2023) — provisional operational license in Dubai; HQ moved to Dubai
UAE is a global crypto hub — VARA (Dubai, 2022) is the world's first independent crypto regulator; ADGM FSRA is more conservative; multiple exchanges licensed
This matters because it determines which regulatory body has authority over your case — and whether you have a direct complaint path or need cross-jurisdictional legal action.
Good news: Since Bybit is registered with VARA (Virtual Assets Regulatory Authority, Dubai) + ADGM FSRA (Abu Dhabi) + CBUAE (Central Bank), we have a direct regulatory complaint path. If Bybit doesn't resolve your case within a reasonable time, we escalate to VARA (Virtual Assets Regulatory Authority, Dubai) + ADGM FSRA (Abu Dhabi) + CBUAE (Central Bank) — and the platform knows this.
under Federal Decree-Law No. 20/2018, you can complain to UAE FIU; VARA-specific complaints to VARA; ADGM complaints to FSRA
Under UAE Federal AML Law No. 20 of 2018 + VARA Rulebook (Dubai) + ADGM FSMR (Abu Dhabi), Bybit must conduct customer due diligence and can freeze accounts during AML investigations. However, they must also:
If Bybit doesn't meet these obligations, we escalate to VARA (Virtual Assets Regulatory Authority, Dubai) + ADGM FSRA (Abu Dhabi) + CBUAE (Central Bank) and file a formal legal submission. For a broader comparison of how United Arab Emirates's rules stack up against other jurisdictions, see our AML laws by country reference.
no personal income tax in UAE; no crypto-specific capital gains tax (federal level)
If your Bybit account is frozen, you may still need to declare your crypto holdings on your United Arab Emirates tax return — even if you can't access them. Under United Arab Emirates law, the tax obligation may apply regardless of whether the funds are accessible. We recommend consulting a Emirati tax advisor.
If the freeze causes you to miss a tax deadline, we can provide documentation for the VARA (Virtual Assets Regulatory Authority, Dubai) + ADGM FSRA (Abu Dhabi) + CBUAE (Central Bank) and tax authority explaining the situation.
A Emirati investor received a source-of-funds demand from Bybit after receiving a large crypto transfer. Bybit required full documentation under UAE Federal AML Law No. 20 of 2018 + VARA Rulebook (Dubai) + ADGM FSMR (Abu Dhabi). We compiled a structured source-of-funds package with bank statements, exchange history, and VARA (Virtual Assets Regulatory Authority, Dubai) + ADGM FSRA (Abu Dhabi) + CBUAE (Central Bank)-compliant documentation. Funds were released within 3 weeks after our formal legal submission to Bybit's compliance team.
Details anonymized to protect client confidentiality. Swiss professional secrecy applies.
We analyze your Bybit account, transaction history, and United Arab Emirates regulatory context to identify the exact trigger. Was it a Chainalysis risk flag? A sanctions screening match? A source-of-funds demand? Each requires a different strategy.
We prepare documentation compliant with UAE Federal AML Law No. 20 of 2018 + VARA Rulebook — not just Bybit's standard templates. This includes source-of-funds proof, transaction tracing, and any required VARA-specific forms.
We submit through Bybit's compliance channels — not standard support. Our submission is in English and references VARA guidelines. We also file a parallel complaint with VARA if needed.
We verify everything works and advise on preventing recurrence on Bybit. If Bybit doesn't respond within no statutory maximum; VARA expects resolution within 30 business days, we escalate to VARA and pursue cross-jurisdictional action in Dubai, UAE (formerly British Virgin Islands) if needed.
Tell us what happened. A senior crypto compliance lawyer — not a chatbot, not a junior — will read your case and respond within 6 hours. Swiss professional secrecy applies from your first message.