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VARA Compliance
Independent VASP security testing for Dubai virtual-asset businesses
Black Cell provides independent penetration testing for Virtual Asset Service Providers (VASPs) operating in Dubai or preparing for a VARA licence.
We test the applications, infrastructure, cloud environments, wallet workflows and smart contracts that support your regulated virtual-asset activity — and provide clear, audit-ready evidence for security, compliance and leadership teams.
Who is this for?
Crypto exchanges
Broker-dealers
Custody providers
Lending and borrowing platforms
VA management and investment providers
VA transfer and settlement providers
Advisory businesses with regulated platforms
Token issuers and smart-contract projects
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Meet VARA’s testing expectations with confidence
The current VARA Technology and Information Rulebook requires VASPs to engage a qualified, independent third party for vulnerability assessments and penetration testing:
- At least annually
- Before introducing new systems, applications or products
- With documented evidence available to VARA upon request
Where smart contracts are relevant to the business, the scope must also cover their effectiveness, enforceability and robustness.
The current Rulebook took effect on 19 June 2025. This is why VARA VASP penetration testing should be treated as a continuous security and compliance activity — not a one-off exercise.
What we test
- Web applications and APIs
- Infrastructure and cloud environments
- Wallet and custody security
- Blockchain and smart contracts
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How the engagement works
- Scope
We identify your regulated activities, critical systems, planned releases and third-party dependencies. - Test
Our consultants perform controlled, manual penetration testing. We validate real attack paths rather than producing scanner output alone. - Report
You receive a business-focused executive summary and detailed technical findings with clear remediation guidance. - Remediate and retest
We support your technical teams during remediation and verify fixes for a documented closure record.
Deliverables
- Independent penetration-testing report
- Executive summary for leadership and compliance
- Rulebook-mapped scope and findings
- Technical evidence and remediation guidance
- Risk-ranked remediation tracker
- Retest report and closure evidence
- Optional smart-contract audit report
- Optional annual VAPT programme or TLPT-readiness support
Rulebook-focused evidence
Our VASP Cybersecurity Assessment is designed to support the areas most relevant to the VARA Technology and Information Rulebook:
|
Rulebook area |
Black Cell output |
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Technology governance and risk assessment |
Scope rationale, threat model and risk-based findings |
|
Cryptographic keys and VA wallets |
Wallet, access-control and key-management assessment |
|
Testing and audit |
Independent VAPT report, remediation tracker and retest evidence |
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Digital operational resilience |
Testing roadmap and remediation-validation support |
|
Smart contracts, where relevant |
Independent audit and exploit-focused technical report |
We can also help prepare for a VARA-directed Threat-Led Penetration Test (TLPT), including safe scoping, external-tester documentation and remediation evidence.
VARA Security Testing Packages
VARA Licence Readiness Assessment
For VASPs preparing for licensing or formalising their cybersecurity programme.
Includes:
• Rulebook-focused security-gap review
• Risk-based scope for critical systems
• Web, API, infrastructure or cloud penetration test
• Prioritised remediation roadmap
• Testing-evidence template for compliance teams
Annual VARA VAPT Programme
For licensed VASPs that need recurring independent testing and clear audit evidence.
Includes:
- Annual independent vulnerability assessment and penetration testing
- Coverage of agreed critical applications and infrastructure
- Executive and technical reporting
- Rulebook-mapped evidence pack
- Remediation retest and closure documentation
Pre-Launch / Advanced Security Testing
For new products, wallet flows, cloud deployments, smart contracts or significant integrations.
Includes:
• Release-focused threat modelling
• Targeted penetration testing before go-live
• Smart-contract audit where relevant
• Go-live risk summary and remediation support
• Optional TLPT-readiness support for high-risk or critical environments
Why Black Cell
A Dubai crypto pentest needs to consider more than a website.
We test the real paths that matter to a VASP: client accounts, withdrawal flows, privileged access, cloud environments, APIs, wallets, keys, smart contracts and third-party infrastructure.
Black Cell delivers:
• Independent, ethical security testing
• Manual exploit validation
• Reporting for engineering and compliance stakeholders
• Security expertise across Web2, cloud and Web3 environments
• Clear evidence to support your VARA compliance programme
We do not issue regulatory approval or claim to guarantee compliance. We provide the independent testing evidence and remediation clarity required to manage cybersecurity obligations properly.
FAQ
Is VARA penetration testing mandatory?
Yes. VARA Rule I.E. requires qualified, independent third-party vulnerability assessment and penetration testing at least annually and before new systems, applications or products are introduced.
Does this apply only to exchanges?
No. The requirement applies to VARA-licensed VASPs. Scope should reflect the VASP’s licensed activities and technical environment.
Are smart-contract audits included?
They can be. Where smart contracts are relevant to the VASP’s business and activities, VARA requires their effectiveness, enforceability and robustness to be assessed.
What is TLPT?
Threat-Led Penetration Testing is an advanced, intelligence-led red-team exercise. VARA may require it where it considers it necessary and proportionate to the VASP’s risk profile.
