FATF Updates NRA Toolkit: VARA Was Ahead, as Digital Assets Go Mainstream
The Financial Action Task Force (FATF) has issued updated annexes to its Money Laundering National Risk Assessment (NRA) Toolkit. The refresh zeroes in on four areas where regulators often face challenges: corruption, virtual assets and VASPs, legal persons and arrangements, and the informal economy.
These annexes provide structured checklists, case studies, and data sources to help countries measure risks more effectively. For many jurisdictions, the update is a necessary step in strengthening AML/CFT regimes that have lagged behind financial innovation.
VARA’s Head Start
While FATF is urging countries to address these areas, Dubai’s Virtual Assets Regulatory Authority (VARA) had already embedded them into its regulatory framework.
Virtual Assets & VASPs
FATF now highlights the importance of assessing VASP markets and delivery channels. VARA had already established a tiered licensing regime and launched the Sponsored VASP framework in early 2025, creating ongoing supervision and reporting duties.
Beneficial Ownership & Legal Persons
FATF emphasizes accurate beneficial ownership data and registry enforcement. Since 2023, VARA has required licensees to comply with UAE Ministry of Economy BO disclosure rules, ensuring transparency and accountability well before FATF’s update.
Corruption & PEP Oversight
The FATF annexes stress monitoring politically exposed persons (PEPs). VARA’s AML Rulebook already requires enhanced due diligence on PEPs, integrated into licensing and compliance obligations.
Informal Economy & Inclusion
FATF points to financial exclusion and reliance on cash as vulnerabilities. The UAE, through VARA and the Central Bank’s payment token regulations, is tackling this by enabling regulated stablecoin frameworks and expanding digital asset rails for payments.
Beyond Dubai: A Global Shift
FATF’s refresh is part of a larger movement. In the United States, lawmakers are advancing the Genius Act and the Clarity Act, both designed to provide greater certainty and oversight for digital assets. Together with frameworks like VARA’s, these initiatives signal that digital assets are now fully mainstream.
What was once a fringe industry is now at the center of financial policy. FATF’s frequent updates, US legislative momentum, and VARA’s proactive stance all underline the same reality: regulators worldwide are racing to keep pace with innovation.
The FATF’s 2025 NRA update may be a wake-up call for many countries, but Dubai’s VARA demonstrates what it means to anticipate risks and act early. With the US also advancing through the Genius and Clarity Acts, it is clear that digital assets are no longer experimental — they are shaping the financial systems of tomorrow.
