Bank and EMI accounts for a licensed VASP in the UAE, the EU and India: what the bank checks, and in what order
A VASP bank account, or an EMI account for a VASP, is opened by the account provider’s own rulebook, not by the licence; the licence gets you to the door. In the UAE, Zand publishes a VASP banking page and Commercial Bank of Dubai announced dedicated VASP accounts in a release of 29 July 2024 (read 7 November 2026). Every UAE bank applies the Central Bank’s guidance for licensed financial institutions on virtual assets (dated 20 February 2023), which asks for the UAE licence or a no-objection certificate addressed to the bank, the AML programme and senior management approval. In the EU, client funds must sit at a credit institution under MiCA Article 70(3), and the EBA’s guidelines of 31 March 2023 bar blanket refusal of a whole category and require every individual refusal to be documented with reasons. In India there is no VASP licence and, on our reading at 7 November 2026, no bank publishes a VASP onboarding policy: FIU-IND registration first, then due diligence under the RBI circular of 31 May 2021. Everywhere, the bank’s file is built with the licence file, the bank is engaged before the licence issues where the rulebook needs an account, and client money moves only after it.
For the operator holding or applying for a VARA licence, MiCA CASP authorisation or FIU-IND registration, not the retail saver. Linked, not restated: whether a Dubai licence guarantees a bank account (VARA licensing); the evidence list, the IDQ and officer residency (the UAE VASP checklist); the PI or EMI licence question (stablecoin payments); the programme (the crypto AML programme); FIU-IND registration (explainer, service).
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Who says, on their own page, that they onboard VASPs
Each row is the provider’s own words: appetite, not an offer. None is endorsed.
| Provider | Regulator and licence type | Bank or EMI | What it says it onboards | Condition on the page | Page read |
|---|---|---|---|---|---|
| Zand Bank PJSC (UAE) | CBUAE-licensed bank; VARA custody licence VL/2024/12/001 (9 December 2024) | Bank | VASPs as a sector: “compliance-first banking for virtual asset service providers” | None stated; the CBUAE guidance gate applies | 7 November 2026 |
| Commercial Bank of Dubai (UAE) | CBUAE-licensed bank | Bank | Release of 29 July 2024: dedicated VASP accounts for client money and prudential requirements under CBUAE and VARA rules (no product page on its site) | None stated; same gate | 7 November 2026 |
| Narvi Payments Oy Ab (EU) | Finnish EMI, FIN-FSA registration 3190214-6, EU-passported | EMI | Web3 and crypto accounts: SEPA and SWIFT IBANs for exchanges, custodians, OTC desks | AML policy, licence or proof of registration, risk assessment, independent AML officer; limited account while a licence is pending | 7 November 2026 |
| Clear Junction Limited (UK, outside the EU) | FCA-authorised EMI, FRN 900684 | EMI | “Licensed institutions only”: EUR and GBP collection and settlement accounts, virtual IBANs | Not for unlicensed entities, cash-heavy models, nested flows, mixers or opaque structures; carried for the GBP rail | 7 November 2026 |
| India | RBI-regulated banks; FIU-IND registration on the VASP side | Bank | No Indian bank publishes a VASP onboarding policy we could read (our reading) | RBI circular of 31 May 2021: ordinary CDD under KYC, AML and CFT standards, the PMLA and FEMA | 7 November 2026 |
A second EU provider was read but not carried. Who is licensed in Dubai is on the VARA register explained.
Why the licence does not get you the account
Because the bank answers to a different regulator, reading a text that tells it to judge you.
The UAE: the Central Bank’s guidance for LFIs. The CBUAE guidance for licensed financial institutions on risks related to virtual assets and VASPs is dated 20 February 2023 on its cover and was announced 31 May 2023 per the CBUAE press release (release not read). It is guidance, not legislation (section 1.1). Section 2.3 bars any relationship with an unlicensed VASP; a foreign licence does not count. Section 4.2.2 sets the file (Table 2) and expects senior management approval; 4.2.3.1 lets the bank interview the compliance officer or visit, and expects exit from a high-risk VASP whose risk it cannot manage. A bank that rejects or exits a duly licensed UAE VASP is expected to notify the licensing authority immediately with its findings.
The EU: the EBA on de-risking. The EBA’s Opinion on de-risking (EBA/Op/2022/01, announced 5 January 2022) says de-risking can be legitimate or a sign of ineffective ML/TF risk management, and asked the Commission to use the PSD2 review on payment institutions’ access to banks’ accounts, the problem behind every EMI account. Its guidelines of 31 March 2023 (EBA/GL/2023/04) set three duties: no blanket refusal of entire higher-risk categories (paragraph 10); consider and reject all reasonably applicable mitigating measures first (paragraph 12); document every refusal and its reasons for the supervisor (paragraph 14). They apply three months after publication in all EU official languages. PSD2 Article 36 gives payment institutions objective, non-discriminatory and proportionate access to banks’ payment accounts.
India: the RBI circular of 31 May 2021. RBI/2021-22/45 told all banks, NBFCs and payment system providers that the 6 April 2018 circular was set aside by the Supreme Court on 4 March 2020 in IAMAI v RBI and cannot be cited, and that due diligence continues under KYC, AML and CFT standards, the PMLA 2002 and, for overseas remittances, FEMA. We found no RBI list of banks that serve VASPs and no RBI guidance to banks on VASP customers (7 November 2026); registration is not a licence.
The bank’s VASP onboarding file, item by item
Seven items, each mapped to the text the compliance officer reads.
| Item | Who asks | The text | What good looks like | Owning page |
|---|---|---|---|---|
| 1. Licence or application status | All; the UAE LFI as a hard gate | CBUAE 2.3, 4.1, 4.2.2: licence or NOC addressed to the LFI; Narvi: licence or proof of registration | A letter addressed to that bank; in India the FIU-IND registration | VARA register; the IDQ; FIU-IND |
| 2. AML, CFT and CPF programme and named officer | All | CBUAE 4.2.2: written programme or a questionnaire such as Wolfsberg, independent audit, annual model validation; EBA/GL/2023/04 paragraph 12: mitigating measures weighed before refusal | Board-approved programme, last audit, model-validation report | Crypto AML programme; residency on the checklist |
| 3. Flow-of-funds diagram and fiat perimeter | All | MiCA Article 62(2)(k): segregation of clients’ crypto-assets and funds described in the application; Article 70(4): payment services via PSD2-authorised providers only | One diagram per fiat leg: who is regulated for it, where client money sits | PI or EMI as well as CASP |
| 4. Source of funds and wealth of the UBOs | All, as standard CDD | Ordinary due diligence under each AML law; the RBI circular of 31 May 2021 preserves it | The capital’s path from declared wealth to the account that holds it, FEMA and ODI first | UAE VASP checklist; capital by activity |
| 5. Monitoring, blockchain analytics and travel-rule vendors | UAE LFI explicitly; others via the programme | CBUAE 4.2.2: annual independent model validation of monitoring and screening; travel-rule recordkeeping under Articles 27 and 33 bis 1 of the AML-CFT Decision | Vendor named, validation report dated, threshold and data set per regime | The travel rule compared |
| 6. Client-money segregation and reconciliation | The bank holding the client account | VARA Part IV: Client Account at a Third-Party Bank, reconciled daily against its statements (IV.E); MiCA Article 70(3): client funds at a credit institution or central bank | Structure and reconciliation written before the application | VARA licensing; MiCA authorisation |
| 7. Group structure and the regulated entity’s place | All; Clear Junction declines opaque structures | CBUAE 2.3: a foreign licence does not substitute. VARA client money rules: the bank holding client money must be outside the VASP’s group (rule cited on VARA licensing) | The licensed entity is the account holder; each leg shows its regulator | Licence taxonomy; the checklist |
“What good looks like” is our practice reading; Wolfsberg is the guidance’s example, not a requirement.
Licence or account first, by regime
The rulebooks imply the sequence. No licence obliges a bank to open the account.
| Regime | What must exist before the account | What the account must exist before | Owning page |
|---|---|---|---|
| VARA (Dubai outside the DIFC) | The licence or an NOC addressed to the bank (CBUAE 4.2.2); on our reading bank engagement starts at the IDQ stage, because the capital rule needs an account | Paid-up capital: the Company Rulebook’s capital rule puts it at a licensed UAE bank, with one alternative, so the bank is engaged before the licence issues (rule cited on VARA licensing). Client money: once the licence issues (CBUAE 4.2.2), only at a deposit-taking bank outside your group (same page) | VARA licensing; the IDQ; amounts on VARA cost and capital |
| MiCA CASP (EU) | The segregation procedure in the application (Article 62(2)(k)); authorisation from the home regulator. Where the MiCA authorisation programme is engaged: Infinilex quarterbacks, EU local counsel files | Client funds: a credit institution or central bank by the next business day (Article 70(3)). Payment services: PSD2-authorised providers only (Article 70(4)); a CASP that is itself an EMI, PI or credit institution is outside 70(2) and (3) (70(5)) | MiCA authorisation; PI or EMI as well as CASP |
| FIU-IND (India) | Registration as a reporting entity under the PMLA; no licence exists (mechanics on the FIU-IND pages) | The bank’s due diligence under the RBI circular of 31 May 2021: KYC, AML and CFT, the PMLA, and FEMA for any overseas remittance | FIU-IND registration; the service |
A US entity’s account is sequenced on the EIN and US bank account page; an issuer’s reserve account is on stablecoin issuance.
Bank or EMI
“EMI account for VASP” is typed by operators declined by banks and pointed to an e-money institution: a real route, not a bank account.
| Point | Deposit-taking bank | EMI or payment institution |
|---|---|---|
| Deposit protection | EU: EUR 100,000 per depositor (DGSD Article 6(1)); UAE: no scheme figure cited here | Not a deposit (EMD2 Article 6(3)); outside the guarantee scheme (DGSD recital 29) |
| Safeguarding | Prudential rules and the scheme | EMD2 Article 7(1): segregation or insurance under the payment services rules, not deposit insurance |
| Refusal, review and exit | EBA/GL/2023/04 paragraphs 10, 12, 14; CBUAE 4.2.3.1 expects exit where risk cannot be managed | Same EBA guidelines; its own bank access runs on PSD2 Article 36 |
| Rails | Domestic rails | Narvi: SEPA and SWIFT IBANs; Clear Junction: EUR and GBP accounts, virtual IBANs |
| Client-money eligibility | VARA: a deposit-taking bank outside the group (rule cited on VARA licensing); MiCA Article 70(3): a credit institution or central bank | Not eligible under either, on our reading |
| Concentration | One bank for capital and client money is a single point of failure | An operating rail beside a bank, not the only account |
One group, three regimes, one file
A group running a Dubai VASP, an EU CASP and an Indian reporting entity shows one programme to three banks: the UAE bank will not take the EU licence in place of the UAE one, the EU credit institution works through the EBA guidelines and MiCA’s client-funds rule, the Indian bank runs CDD under the RBI circular. The seven items do not change; their versions do. Build the file once with the crypto AML programme as its spine, then cut a version per bank. Infinilex does not secure or accelerate an account: the bank decides, and no provider publishes a timetable it is bound to keep.
Who signs what
Infinilex counsel qualified in India, the UAE and the US sign opinions for those jurisdictions; for the EU and any other jurisdiction Infinilex scopes and coordinates the local counsel who sign. Infinilex’s in-house chartered accountant handles the FEMA and ODI record behind the capital; UK counsel are coordinated for GBP rails.
Frequently asked questions
What is an EMI account for a VASP, and is it the same as a bank account?
No. An EMI is an electronic money institution: under Article 6(3) of the EU E-Money Directive the funds it receives are not a deposit, and Article 7(1) safeguards them by segregation or insurance, not deposit insurance. Bank deposits are covered to EUR 100,000 per depositor; e-money is not (DGSD recital 29). The VARA client money rules and MiCA Article 70(3) put client money at a deposit-taking bank or credit institution, so on our reading an EMI carries operating payments, not client money.
How do we open a VASP bank account in the UAE once we hold a VARA licence?
By satisfying the CBUAE guidance for licensed financial institutions on virtual assets and VASPs (dated 20 February 2023). Section 4.2.2 expects the bank to obtain your UAE licence or a no-objection certificate addressed to it, assess your AML and CFT controls, confirm independent audit and annual model validation, check the travel rule and take senior management approval; client money moves only once the licence issues. Zand publishes a VASP banking page and Commercial Bank of Dubai announced dedicated VASP accounts in a release of 29 July 2024 (read 7 November 2026); we endorse neither.
Is there a crypto friendly business bank account for a licensed crypto exchange in the EU?
No bank is obliged to open one, but a refusal has rules. EBA/GL/2023/04 (31 March 2023) bars blanket refusal of whole higher-risk categories (paragraph 10), requires mitigating measures to be considered first (paragraph 12) and requires every refusal to be documented with reasons (paragraph 14). MiCA Article 70(3) puts client funds at a credit institution or central bank by the next business day, so an exchange needs a bank, not only an EMI; Article 70(4) confines payment legs to PSD2-authorised providers.
How do Web3 companies open bank accounts in India when there is no VASP licence?
Register with FIU-IND first, then pass due diligence. The only RBI text is the circular of 31 May 2021: the 6 April 2018 circular was set aside by the Supreme Court on 4 March 2020 (IAMAI v RBI) and cannot be cited, and due diligence continues under KYC, AML and CFT standards, the PMLA 2002 and FEMA. No Indian bank publishes a VASP onboarding policy we could read (7 November 2026), so build the file the bank would otherwise invent: registration, programme and Principal Officer, flow of funds, source of capital.
Building the bank’s file alongside the licence file?
Tell us which regulator has you, where client money will sit and which banks you have approached. We map the file to the texts each bank reads.
Thirty minutes with Prashant Sharma, the founder, who does the work himself. You leave with next steps either way. Email is read by the founder and answered within one working day.
Sources
Read 7 November 2026. UAE: CBUAE guidance for LFIs on virtual assets and VASPs (cover 20 February 2023; announced 31 May 2023 per the CBUAE press release, release not read); VARA Company Rulebook Part VI (capital rule, cited on VARA licensing); VARA Compliance and Risk Management Rulebook Part IV, IV.E; VARA register, Zand Bank PJSC. EU: EBA/Op/2022/01 press release (5 January 2022); EBA/GL/2023/04 (31 March 2023); MiCA (Regulation (EU) 2023/1114, 31 May 2023), Articles 62(2)(k), 70(3) to (5); EMD2 (Directive 2009/110/EC, consolidated 13 January 2018), Articles 6(3), 7(1); PSD2 (Directive (EU) 2015/2366, 25 November 2015), Article 36; DGSD (Directive 2014/49/EU, 16 April 2014), Article 6(1), recital 29. India: RBI/2021-22/45 (31 May 2021). Providers: Zand; Commercial Bank of Dubai release (29 July 2024, via Zawya); Narvi accounts and onboarding; Clear Junction.
General information for operators, not legal advice. Provider rows are each provider’s own words on the date shown; none is endorsed. Texts as at 7 November 2026. The bank decides the account; nothing here can secure or accelerate that decision.