Issue 002 · The Structure · United Arab Emirates, Seychelles
A virtual asset group across Dubai, the Seychelles and the BVI
A familiar shape for crypto businesses, and the reason the holding company at the top has become its weakest link.
Why each piece sits where it does
Licensed operating company
The operating company sits under the holding company and serves clients in and from Dubai under a VARA licence. The staff, the regulator relationship and, usually, the bank account all sit here.
International platform
The international platform sits beside it and serves clients outside the UAE. The Seychelles FSA treats a licence as required by the mere fact that a virtual asset business is incorporated or registered in the Seychelles. That makes this entity a licensing project, not a shelf company.
Holding company
The holding company sits at the top, in the BVI. Since 29 January 2026 the BVI has been on the EU's list of high-risk third countries for money laundering, and it is on the FATF's list of jurisdictions under increased monitoring. It was chosen because investors know it and its corporate law is simple.
Where this goes wrongCARF and banking arrive together. From 2027 each regulated entity may carry its own crypto reporting obligations, on its own jurisdiction's timetable. Meanwhile the bank applies enhanced due diligence to the BVI-linked ownership. It asks about the holding company before it asks about the business.
Our readingThe operating layers work. The holding company is the part to revisit, because a holding entity in a jurisdiction that is not on a high-risk list takes one question out of every bank and counterparty review.
This piece appeared in Jurisdicta, Issue 002. General information only; not legal, tax or investment advice.