Anti-Money Laundering for Crypto Assets Under Dubai's Vara Specialized Authority Model and Lessons for The Vietnam International Financial Centre (VIFC)

In the context of Vietnam urgently shaping the legal framework for crypto assets and operating the Vietnam International Financial Centre (VIFC) in Ho Chi Minh City and Da Nang, researching the management models of leading international financial centers is imperative. This article analyzes the model of the Virtual Assets Regulatory Authority (VARA) inDubai—an independent specialized virtual asset regulatory body established under LawNo. 4of 2022. The focus is on translating anti-money laundering and countering illicit financing (AML/CFT) obligations into binding requirements for virtual asset service providers (VASPs), particularly through regulations on the Travel Rule and risk management of unhosted wallets. Utilizing legal analysis and comparative jurisprudence methodologies, this study contrasts VARA's legal framework with the recommendations of the Financial Action Task Force (FATF) and the practical context of Vietnam. The findings indicate that VARA operates under a highly autonomous specialized authority model, combining risk-based supervision with specific technical requirements (transaction thresholds, risk assessment frequency, and handling of unhosted wallets). Based on these insights, the paper proposes that VIFC establish a specialized regulatory mechanism with clear authority, while internalizing FATF standards fromthe controlled sandbox phase, rather than relying solely on existing general regulations.