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Schedule 1 – Definitions

Term Definition
“AML/CFT” has the meaning ascribed to it in the Regulations.
“Anonymity-Enhanced Cryptocurrencies” has the meaning ascribed to it in the Regulations.
“Anonymity-Enhanced Transactions” means transactions denominated in Virtual Assets which are not Anonymity-Enhanced Cryptocurrencies, but which prevent the tracing of transactions or record of ownership.
“BCDR Plan” means the Business Continuity and Disaster Recovery Plan of a VASP.
“Board” has the meaning ascribed to it in the Company Rulebook.
“Capital and Prudential Requirements” has the meaning ascribed to it in the Company Rulebook.
“CDD” means client due diligence, including but not limited to due diligence on the clientele of a VASP’s client.
“Client Account” has the meaning ascribed to it in Part IV of this Compliance and Risk Management Rulebook.
“Client Money” has the meaning ascribed to it in Part IV of this Compliance and Risk Management Rulebook.
“Client VA” has the meaning ascribed to it in Part V of this Compliance and Risk Management Rulebook.
“CMS” means the compliance management system of a VASP.
“Compliance Officer” or “CO” has the meaning ascribed to it in Part I of this Compliance and Risk Management Rulebook.
“Company Rulebook” means the Company Rulebook issued by VARA pursuant to the Regulations, as may be amended from time to time.
“Compliance and Risk Management Rulebook” means this Compliance and Risk Management Rulebook issued by VARA pursuant to the Regulations, as may be amended from time to time.
“Controlling Entity” has the meaning ascribed to it in the Company Rulebook.
“Decentralised Autonomous Organisation” or “DAO” has the meaning ascribed to it in the Company Rulebook.
“Directive” has the meaning ascribed to it in the Regulations.
“Dubai VA Law” means Law No. [4] of 2022 Regulating Virtual Assets in the Emirate of Dubai, as may be amended from time to time.
“Emirate” means all zones across the Emirate of Dubai, including Special Development Zones and Free Zones but excluding the Dubai International Financial Centre.
“Entity” means any legal entity or individual.
“EOCN” means the UAE Executive Office for Control & Non-Proliferation.
“FATCA” means the United States Foreign Account Tax Compliance Act.
“FATF” means the Financial Action Task Force.
“Federal AML-CFT Laws” has the meaning ascribed to it in the Regulations.
“Fit and Proper Person” means an individual who complies with all fit and proper requirements in the Company Rulebook.
“GoAML” means the electronic platform through which Suspicious Transaction reports can be submitted to the UAE FIU.
“Group” has the meaning ascribed to it in the Company Rulebook.
“Guidance” has the meaning ascribed to it in the Regulations.
“Inside Information” has the meaning ascribed to it in the Regulations.
“Insolvency Proceedings” has the meaning ascribed to it in the Regulations.
“Licence” has the meaning ascribed to it in the Regulations.
“Licensed” means having a valid Licence.
“Market Conduct Rulebook” means the Market Conduct Rulebook issued by VARA pursuant to the Regulations, as may be amended from time to time.
“Money Laundering Reporting Officer” or “MLRO” has the meaning ascribed to it in Rule III.A.1 of this Compliance and Risk Management Rulebook.
“Outsourcing” has the meaning ascribed to it in the Company Rulebook.
“Politically Exposed Person” or “PEP” has the meaning ascribed to it in the Company Rulebook.
“PDPL” means the Federal Decree-Law No. [45] of 2021 on the Protection of Personal Data.
“Personal Data” has the meaning ascribed to it in the PDPL.
“Regulations” means the Virtual Assets and Related Activities Regulations 2023, as may be amended from time to time.
“Related Parties” has the meaning ascribed to it in the Company Rulebook.
“Reserve Assets” has the meaning ascribed to it in the Company Rulebook.
“Responsible Individuals”   has the meaning ascribed to it in the Company Rulebook.
“Rule” has the meaning ascribed to it in the Regulations.
“Rulebook” has the meaning ascribed to it in the Regulations.
“Senior Management” has the meaning ascribed to it in the Company Rulebook.
“Staff” has the meaning ascribed to it in the Company Rulebook.
“Suspicious Transaction”
means any transaction, attempted transaction, or funds which a VASP has reasonable grounds to suspect as constituting, in whole or in part, and regardless of the amount or the timing, any of the following—
[a] the proceeds of crime [whether designated as a misdemeanour or felony, and whether committed within the Emirate or in another country in which it is also a crime];
[b] being related to the crimes of money laundering, the financing of terrorism, or the financing of illegal organisations; and
[c] being intended to be used in an activity related to such crimes.
“Technology and Information Rulebook” means the Technology and Information Rulebook issued by VARA pursuant to the Regulations, as may be amended from time to time.
“Third-Party Bank” has the meaning ascribed to it in Part IV of this Compliance and Risk Management Rulebook.
“Travel Rule” has the meaning ascribed to it in FATF’s Updated Guidance for a Risk-Based Approach for Virtual Assets and Virtual Asset Service Providers [October 2021], as may be amended from time to time.
“UAE” means the United Arab Emirates.
“UAE FIU” means the UAE Financial Intelligence Unit.
“Ultimate Beneficial Owner” or “UBO” has the meaning ascribed to it in the Company Rulebook.
“VA Activity” means the activities listed in Schedule 1 of the Regulations, as may be amended from time to time.
“VA Wallet” has the meaning ascribed to the term “Virtual Asset Wallet” in the Dubai VA Law.
“VARA” means the Dubai Virtual Assets Regulatory Authority.
“VASP” means an Entity Licensed by VARA to conduct VA Activity[ies] in the Emirate.
“Virtual Asset” or “VA” has the meaning ascribed to it in the Dubai VA Law.