VARA 副主席 Deepa Raja Carbon：Dubai 如何建立加密監管制度

0:00Dubai 的加密故事與 VARA 的誕生

0:00我們今天要聊聊隨著加密產業全球擴張，Dubai 和阿聯酋在這波浪潮中發生了什麼事。很榮幸邀請到 VARA 副主席 Deepa Raja Carbon 來分享她的經驗。這場對談的目標很簡單，就是讓大家了解 Dubai 的故事，不只是現在的狀況，還有未來的願景，讓你在規劃全球政策時能有更多資訊參考，也思考 Dubai 和阿聯酋是否適合你設立據點。Deepa，很高興你今天來到現場。Now we're going to talk about, as we're expanding around the world in crypto, we're going to talk about Dubai and the UAE, and really what's happening in Dubai when it comes to crypto. And we're very, very honored to be joined by the Vice Chair of VARA, Deepa Raja Carbon. I'll introduce her in a second. My goal with this session is very simple, is to share with you here the Dubai story, not only what's happening now, but also the vision, where things are heading, and hopefully empower you with this information as you're making your plans on a global policy perspective, where to set up. We'll see if Dubai and the UAE has a role in that. Deepa, great to have you with us today.

0:45謝謝邀請我來。順帶一提，這也展現了 Dubai 當局的承諾——Deepa 住在辦公室旁邊，走路 10 公尺就到，甚至還有地下通道直通辦公室。對其他監管機關來說，這就是承諾的象徵，沒藉口說塞車遲到。當然，作為監管者，也要有工作與生活平衡，不只是團隊要有，領導者也需要。Thank you for having me. Fun fact, by the way, by Deepa, this is a commitment of the Dubai authorities. Believe it or not, she lives literally next to her office. There's the VARA offices, and she's literally 10 meters, even an underground corridor for her to come to the office. I think for any other regulator listening to this, this is a sign of commitment. No excuse for being caught in traffic afterwards. That's true. No excuse, but that also says that, you know, as a regulator, I should be able to have—I mean, we often talk about work-life balance, right? The team's supposed to have one, not the person that's sitting on top of it. So.

1:21從業務持續營運（BCP）的角度來看，這樣也很方便。可以請你跟大家分享一下你的背景、你在 Dubai 的經歷，以及 VARA 是怎麼誕生的嗎？Also from a BCP perspective, right? You have it all there. Can you share with our audience a bit of your background, I think your journey, everything you've done in Dubai, but also how the genesis behind VARA, and then we'll go deeper afterwards.

1:35Dubai 的開放與新經濟規劃

1:35我在 Dubai 已經快 21 年了，早期在美國，後來搬到 Dubai，最初在 Dubai World Trade Center 工作。Dubai 最吸引我的地方是這裡不會把你框住，不管你職涯怎麼開始，未來發展都取決於你自己。這也是這座城市和領導層的精神。後來我加入 Dubai 經濟部，COVID 期間我們提出了 D33 計畫，聚焦新經濟，包括虛擬資產、區塊鏈、元宇宙、AI 等，底層其實就是加密世界。那時 Dubai 很快意識到全球大多數國家都沒監管這個產業，所以我們決定設立一個監管機構，讓這產業能被規範和立法，這就是四年前我開始創建 VARA 的原因。Sure. Look, I've been in Dubai for almost 21 years, right? So the early part of my life was in the U.S., and then I moved up to Dubai to work with the Dubai World Trade Center, which is an event and exhibition center, but—The thing about Dubai that I find quite fascinating is they never box you in, right? It doesn't really matter where your career begins. How your career evolves is very much based on who you are and what you want to do with it. And I think that's very much the genesis of the city as a whole, the leadership as well as most of the population that comes in there. I moved into, I used to work with Dubai Economy. Through COVID, and at that time we came up with the D33 plan, the Dubai 33 plan, which was very much about the new economy, whether it was virtual assets, but virtual assets was sort of the underlying, but it was very much about blockchain, metaverse, AI and such like. And underlying all of that was the world of crypto. And that's also when Dubai very quickly realized that most of the world doesn't regulate this sector, and it wasn't at that time. So what if we set up a regulator and made this a completely regulator-bull and legislatable industry? That's kind of why I came around to setting up VARA about four years ago.

2:54這段旅程真的很棒。你可以跟大家分享一下 VARA 現在的規模嗎？因為這幾年成長真的很驚人。Absolutely fantastic journey, I have to say. Can you share maybe some stats with the audience where—Vara is right now, because I think it's quite impressive growth the last couple of years.

3:05截至今天早上，VARA 已經有 58 家持牌機構，這些都是完全受監管的公司。另外還有超過 200 家有註冊、NOC 等資格。如果你看全球持牌加密機構的數量，Dubai 是全球最大的管轄區。So, well, Vara is currently at 58 as of this morning, licensed entities. And when we say licensed, we mean fully regulated entities. We've got a whole bunch, I think more than 200 of them that have—Registrations, NOCs and such like. And so if you look at just registered entities, or meaning licensed entities across the world, you'll find that this is the largest jurisdiction for licensed crypto.

3:29Dubai 加密產業的聚落效應與監管哲學

3:29身為在這裡持牌的公司，我覺得最不可思議的是，所有對手方都在附近，走路一分鐘就能碰面。想像一下，如果所有加密公司都在同一棟大樓，大家隨時可以交流，這真的很棒。這種生態系的互通性很重要，不只是交易所，還有券商、資產管理、託管、銀行夥伴等，這樣產業才能真正成長。這也是吸引人才來 Dubai 的關鍵。And I can say as a firm who's licensed there, what I find incredible is I'm literally one minute walk away from all my counterparties. Means crypto firms don't realize. Imagine if all the crypto firms were in—One tower of MBS, and everybody is there. It's incredible. Often the thing is just happening, but just bumping into people as well. Indeed. This is an important point that you make, right, Henry? To us, it was important that we, I mean, of course, most regulators start with exchanges, as we did too. You get the bulk of the audience there. But if you don't have the entire gamut, if you don't have the—Broker-dealers, asset managers, custodians, banking partners, etc., then the industry simply doesn't grow. So that interoperability, even within the ecosystem, is almost fundamental. That's the only way talent comes to your country, right?

4:14這兩天在會議上，大家常抱怨監管機關不了解產業。但 VARA 不一樣，我常半開玩笑說，VARA 的好處是他們真的懂這個領域，壞處也是他們太懂了。這種專業度對 VARA 的成功有多大幫助？What have you found on the, you know, one, even this last two days at the conference, it's been coming up a lot, is that people are complaining that often regulators don't understand the space. What's been incredible with Vara is, I always tell people half jokingly that the good thing with Vara is they know what they're doing. The bad thing with Vara is they know what they're doing, you know, because there's so much expertise within the regulator. You know, to what extent do you believe that was an edge that basically helped in the success of Vara?

4:43VARA 的專家大多來自傳統金融（tradfi），而且我們沒有人是職業監管官，這其實很重要。我們都來自私部門，知道怎麼讓產業運作，也懂得傾聽產業需求，並調整我們的思維。這些專業是隨著產業一起成長的，不是天生就有，而是謙虛地向產業學習，贏得尊重。So when you say expertise, it's an interesting one, right? Most of our... Experts within VARA are tradfi, right? And we're also extreme—I mean, none of us are regulators, which is almost essential, I think. We're all people that are from private sector. We understand what it takes to make private sector work. And also, as a consequence, we're there to listen, right? We're there to listen to the industry on what—You guys need to make your businesses successful and adapt our thinking to where you're coming from. So the consequence, I would say, our expertise has evolved with the expertise of the industry. We didn't come born with that expertise, but we've been very, I mean, humble enough to be able to gain that respect from the industry as well, is what I would say.

5:35監管與產業的互動與未來展望

5:35你提到傾聽，這是 VARA 做得非常好的地方。加密社群早期最希望的就是監管機關願意聽、願意接受，然後制定大家都能遵守的規則，至少有公平競爭的環境。你不能監管你不懂的東西，否則規則沒人理會也沒意義。所以我們一直在問：你們怎麼演進、怎麼思考？從 2019 到現在，變化非常大。那未來的願景是什麼？如果五年後我們再開這場會，你覺得 VARA 會變成什麼樣子？You know, you said listen. I think that's the one great thing that I think Varad did fantastically well. I think that's what the crypto community was asking, especially in the early days. We just wanted actually regulators that were happy to listen, accept, and actually come up with a set of rules that we can all abide to it, but at least we know there's a level playing. But you cannot regulate something you don't understand, right? We can come with a set of rules that nobody follows. What's the point of that? So it was very much about saying. How are you evolving? How are you guys thinking about it? And even if you look at your own world, from 2019 to today, that's evolved so much, right? And what's the vision now? You think if we're having this session in five years from now, in 2031 here, what do you think? What do you expect Vara to be by then?

6:18五年前如果有人問我這問題，我也很難預測今天的狀況。這產業發展速度超快，不只是為了創新而創新，而是逐漸成熟。你會看到傳統金融（TradFi）和去中心化金融（DeFi）開始融合，這是四五年前無法想像的。這種彼此尊重會讓產業變得更強大。Five years ago, if you were here and you were asked the same question, would you predict where we are now? A hard one, right? It would be a very hard one. And that's what I love about the industry, right? It's evolving at the pace of light, right? And the reality is, it's not evolving for the sake of evolution. It's maturing with it, and you see this convergence of TradFi and DeFi, which you never imagined would happen four or five years ago. So I do think that that level of Respect that you've developed for each other will make this industry quite, quite insurmountable.

6:53Dubai 的韌性與領導力

6:53今年中東局勢很動盪，身為 Dubai 居民，看到從領導層到企業、公司，大家如何應對真的很有意思。你能不能分享一下戰爭對 Dubai 的影響，以及 Dubai 採取了哪些措施來因應？So, Deepa, obviously it's been a challenging year in the Middle East with all the events going on. I think, as somebody who lives in Dubai, it was quite interesting to see how everybody from leadership to companies to businesses dealt with it. I think it would be interesting if you can share with the audience, like, what—With the war going on, how does it impact Dubai, and how actually, what are the measures that are being taken to deal with this?

7:19Dubai 一向反應很快，不是被動應對，而是主動回應。這是我在這城市、在阿聯酋二十年來最深刻的感受。今年二月底開始動盪，但大部分外籍人士，包括你們，並沒有離開，大家都還帶著家人在這裡生活。這是很大的差異，因為有家庭的人不會輕易冒險，孩子還要上學，生活不能被打亂。Dubai 在這方面做得非常好。領導層在動盪發生的第一時間就和產業開會，問我們怎麼做才能讓大家更有安全感，確保生活和商業不被打亂。三個月後，Dubai 其實沒什麼變化，現在連交通又開始塞車了。Look, I think anybody that knows Dubai also knows that we are extremely responsive, right? We normally aren't reactive to disruption, but extremely responsive to it. And that's something I've seen for this city, of course for the UAE as a whole. Over the two decades that have been there, probably more than any other jurisdiction, right? But in this particular context, February, end of Feb, was when all of this disruption actually started. But if you think about, I mean, yourselves included, most of the expats that live there, you didn't see many of them leave. You're still there, and you're there with family. And I think that's a big differentiator, right? When a person is there as an individual, they're a little bit more willing to take a lot of risks. But when you're there with your wife, your kids, and children have to go to school, and just, you know, the regularity of life. Can't be disrupted. And I think Dubai's done a phenomenal job of that. I mean, more than me, you should ask yourself, right? That's been the genesis of how the leadership has actually dealt with it. It was the very first meeting was had by the leadership with the industry in February, as soon as the disruption broke out. And their whole purpose was to say, what is it that we can do for you to make you feel safer? In this place, in a situation that we can't really control, and it's not in our control for the large part, right? But what can we do to ensure that businesses don't get disrupted, life doesn't get disrupted, and three months out, you didn't see very much change in Dubai. Fortunately, I think traffic is back in Dubai now. Traffic is back in Dubai, indeed.

9:04Dubai 領導力與國際吸引力

9:04你覺得 Dubai 領導層為什麼總是這麼主動、願意傾聽？我認為這個城市是由人民打造的，吸引了來自全球 200 多個國籍的人，這裡就像世界的縮影。大家彼此支持，對這個國家有很強的歸屬感，來了就很難離開，因為你真的會愛上這裡。I've always been wondering this. What, in your opinion, not motivates, but is the genesis of leadership being so on top of things, like being proactive, listening to people? Look, I think the city is made from a nation that understands it's built by its people, right? Whoever it attracts from every corner of the world, you've got 200 nationalities that live there, right? It's about the microcosm of the world that you can ask for. And as a consequence, everyone relies on each other being supportive to the nation as a whole. The amount of loyalty you'll find in Dubai towards being—it's a very sticky place, right? It's very hard to leave once you get there. And that's really because it's not because somebody is forcing you to do it, it's because you really want to.

9:54現在很多國家都想成為下一個 Dubai，過去大家想成為新加坡、香港。你覺得他們最常缺乏什麼，導致難以複製 Dubai 的成就？Dubai 有天然優勢，地理位置在世界中心，四到六小時航程內有 20 億人口，市場自然就圍繞著你。雙邊貿易關係也是全球最強之一。雖然人口和地理規模都不大，但 Dubai 建立了可靠的國際聲譽，跨境關係非常穩定。傳統產業和新興產業都能在這裡發展得很好。When you meet, you know, other regulators or other heads of state, and everybody wants to be the next Dubai. Back in the day, everybody wanted to be the next Singapore, the next Hong Kong. What is the one thing often you think they lack that is making difficult to achieve what you've been able to achieve? Look, I'll tell you what. One, of course, Dubai has some natural benefits of being right in the center of the world. Between the four to six hour flight path, you've got, you know, two billion people. So you've got the natural market. That comes around you, right? That's one thing. As far as bilateral trade relations, we probably have the strongest of any nation on the planet, right? And so as a consequence, you naturally have a lot of these parameters that have already been set up. You know that it's a nation that is generally small in terms of the population base, and it's small, right, in terms of geographic presence as well, but—But what it's built for itself in terms of reputation is simply the fact that it can always be reliable, right? You will not find any disruption in the kind of relationship it has with most nations. Global sort of cross-border relations are phenomenal. So traditional industry has always worked extremely well out of Dubai, but you also find that new industry.

11:10COVID 之後我們積極發展新經濟，像 AI、區塊鏈、元宇宙等，現在還有長壽醫療。Dubai 領導層總是思考前沿領域，即使還沒被監管，也會討論怎麼推向市場。最近還成立了 Dubai Longevity Authority，跟幾年前的加密產業一樣，先聽產業意見再制定政策。這些經驗也能應用到新領域。So one of the first things we did coming out of COVID. Pursue a new economy, whether it is AI, blockchain, metaverse, all of those kind of things. But also today, it's the world of longevity, right, and the advancements in preventive medicine as opposed to corrective. So those are the kinds of frontier thinking that the leadership will always think about, and they say it doesn't matter that it's not regulated. Let's talk about how we can bring it to market. It's impressive. I just found out about it recently that there is a—A new regulator being launched in Dubai called the Dubai Longevity Authority. Yeah, that's right. Try to actually exactly like crypto was a couple of years ago. There's all the innovations, how we come up and listen to them and put them together. Yeah. I mean, it's actually, and you can take a lot of the learnings from Vara, ironically, and put them into this Dubai Longevity Authority. Absolutely.

11:56外界對 Dubai 的誤解與產業參與

11:56虛擬資產是大家可以選擇參與或不參與的領域，但長壽醫療是每個人都會關心的，預防勝於治療。這個監管機構今年六月成立，現在已經很活躍。你覺得外界最常誤解 Dubai 的是什麼？如果你想參與下一波創新，Dubai 會是最好的起點，也是能把創新帶向全球的樞紐。很多人以為 Dubai 只是浮誇，但實際來過會發現這裡其實很接地氣、很正常。Look, virtual assets is one thing that people have a choice to say, I participate or don't. Longevity is something that I guess all of us have to, right? It's about where we get to with our lives, and preventive is always better than corrective. So yes, this was a regulator launched back in June and pretty much active right now. What is the one thing you think people get wrong about Dubai from outside? Like the average person who's looking at Dubai from the outside, what do you think they get often wrong? If you want to think about the next frontier of where innovation is going to lie and where you may want to participate, that would be the center. It would be the nexus from where that idea can take root, but more importantly, from where it can be transported to the rest of the world. Interesting. And you think often the—When they look at Dubai, do they still the flashy, and do they get the wrong image? Well, I mean, flashy is always there, right? It's a brand associated with Dubai. But when you come to Dubai, you realize that that is a very different ecosystem. It's very down to earth. It's actually very normal. Yeah, exactly.

13:00你在創建 VARA 的過程中，最讓你驚訝的是什麼？我最驚訝的是產業的合作意願。我們原本以為產業會很有距離感，結果大家都很願意參與、溝通，不是為了打勾完成監管，而是真心想讓產業更負責任。這種轉變大約是 2019 年後開始的。What surprised you the most in this whole experience of building? Vara, like, what was the one thing that you found the most surprising that you didn't expect when you embarked on this journey? I would say the collaboration we got from the industry. We were expecting the industry to be quite standoffish, as I'm sure the industry expects the regulator to be standoffish, right? And we found the level of, I think, willingness to participate, to engage, to actually...Come to the table and have a very humble conversation with the regulator, not because you wanted to get regulated and have a checkbox exercise, right? But really because you wanted to be in a very responsible sector. And that transition happened from, I would say, post-2019. Wow, interesting.

13:50阿聯酋多元監管體系與 Dubai 的嚴格監管

13:50大家常說阿聯酋監管機構很多，像 VARA、CMA、ADGM、DFSA 等，讓人搞不清楚。其實這是一個很有凝聚力的系統。VARA 負責 Dubai 本地和自由區，ADGM 和 DIFC 各有自己的監管機構（FSRA 和 DFSA），主要負責資本市場和 DeFi。CMA 是聯邦層級，負責六個酋長國的資本市場，Dubai 的虛擬資產則由 VARA 監管。我們和 CMA、ADGM、DIFC 都有很緊密的合作，未來也會有更多互通。Comment, we hear a lot about the UAE. There's so many different regulators. It's confusing. You have VARA, you have CMA on the onshore, you have ADGM, you have the FSA. First, I think it would be interesting if you can explain to why that is the case, but how best to deal with that as well for the audience. Look, you're right that there are multiple regulators, but it's a very cohesive system. Once you get to understand it a little bit better. Firstly, VARA regulates mainland and free zones of Dubai. So all of Dubai is regulated by VARA, right? Now, they've got two financial free zones in the UAE. One is the DIFC and the other one is the ADGM. Those two have their own independent regulators, which is the FSRA and the DFSA. So they do not regulate anything on mainland, but they've been there for several years. More capital markets regulators that also do a phenomenal job in the DeFi world. The CMA, which is the Capital Markets Authority, is the federal authority. They regulate six of the seven emirates, and the seventh emirate being Dubai for virtual assets. They regulate capital markets for all of the Emirates. Our relationship with the CMA is phenomenally tight, meaning that there is a lot of cross-pollination that happens between our ecosystems. There will be entities that are licensed by us that could get a passporting with the CMA to be able to operate across the UAE and vice versa. The same with ADGM and DIF. DFSA, they would, in the DIFC equation, we've got MOUs with both those parties. It's not passportable just yet, but that will eventually arise at some point. Yeah.

15:29早期大家以為來 Dubai 很容易，現在其實監管非常嚴格。像我們公司每週都要報告，VARA 的專業讓我們更有信心。其實如果你只是想找個鬆散的地方做事，Dubai 不適合你；但如果你想打造真正的事業、未來的金融，Dubai 非常歡迎你。It's interesting, you know, also the image. I remember in the early days of Dubai, people would think, ah, if you want something easy, quick, we'll come to Dubai. And I tell everybody, even as a regulated firm, we have weekly reporting. You know, and it's the level of actually, the good thing of VARA, because there's so much expertise, you actually feel more comfortable being regulated by a regulator who understands the space. It makes it so much better. But I find it's the image that back in the day people had, it's easy, we go to Dubai. People don't realize how much there's strict supervision. So actually, it's a fantastic point you make. If we wanted to be—The jurisdiction of least resort. We could have easily done that in the first year, right? The fact that you set up a regulator by default means that you really want to try and ensure that the industry is operating for the most responsible, but it's also market integrity, which is foundational, right? I tell everybody, if you're looking for a place to actually just set up and do things half-assed and easy, do not come to Dubai. We don't need you. If you want to build a real business, build a scale, and build the future of money, future of finance, more than welcome. And I'm sure Deepa and the others, Paul and others are in the room, will be happy to welcome you.

16:47Dubai 的開放與全球加密產業的影響

16:47我在這個生態系已經 12、13 年了，過去沒人願意跟我們對話，是 Dubai 和阿聯酋真正敞開大門、願意傾聽，才有今天 VARA 的成功。我相信如果沒有 Dubai 和阿聯酋這兩三年的努力，尤其是在美國政策轉向前，全球加密產業不會有現在的成就。未來加密產業歷史一定會有 Dubai 的一章。But I think it's been great. Really, I speak on behalf of the, you know, I've been privileged to see this ecosystem for the last 12, 13 years. There was a time where nobody wanted to talk to us, literally, and really Dubai, the UAE opened the doors and arms that actually listened to us. And now, I mean, obviously, you're seeing all the success that VARA has had. And I truly believe that without the role that Dubai, the UAE played, especially the last two, three years, especially before the shift of—Policy in the U.S., I don't think the crypto industry would have been where it is right now. So there's really, in the history of crypto, there'll be a chapter on Dubai for sure, for sure on that perspective.

17:26快問快答：個人與政策建議

17:26最後來點輕鬆的快問快答。你最喜歡新加坡什麼？不是天氣，是綠意。那 Dubai 呢？國際化。平常不忙時最愛做什麼？騎腳踏車。現在最讓你有動力的是什麼？想看 VARA 下一步怎麼走，尤其是 TradFi 和 DeFi 如何融合、壯大。如果要給 18 歲年輕人一個建議？監管機關沒你想像中可怕，讀書時可以考慮政策相關領域。回到學校會選什麼課？公共政策。第一份工作建議去哪？私部門，像我第一份工作在顧問公司，打好基礎再進監管機構。最後，如果能跟一個人共進午餐，不論生死，你會選誰？Isaac Newton，因為他啟發了科學的起點。Deepa, anybody comes on stage with me, whether you like it or not, my best friend, the bell is here. So I'm going to ask you quick questions. And I want one or two-word answers, and we're going to take it from there. Sure. Ready? Right, let's go. Here we go. We're in Singapore this week. What's your favorite thing about Singapore? I have to say it's not the weather. It's very comparable to Dubai, but I will say it's green. Here we go. What's your favorite thing about Dubai, having been there for 20 years? I feel the internationalism of the city. It's amazing on that side. What's your favorite thing to do when you're not busy running Vara or the other authorities or anything else? Oh, be on a bike. On a bike? Yeah. Interesting. Okay. What's the one thing that inspires you the most now? Inspires me the most, I will say to see where the next...Genesis of Vara takes us, right? I really would like to see how TradFi and DeFi come together in a way in which it can self-sustain and actually grow phenomenally larger than where it is today. Amazing. If you had one piece of advice to an 18-year-old in the room, what piece of advice would you give them, knowing what you know about policy making and everything else? I would say regulators aren't half as bad as you may think they are. From the outside, and if anybody actually does want to get into the space, when you are studying whatever it is that you are, you should think about policy. What's the one course you would take if you would go back to school today that you wish you had taken back in the day? Public policy. It would be. Public policy. Interesting. If anybody in the room, there's a young person looking for their first job, they're debating between a consulting firm, startup. The government or regulator, which job would you recommend they take? As the first job out of school, I would definitely, definitely think private sector. So you should. Interesting. Yes. I think consulting is where I went as my first job, and I think it gives you a grounding more solid than anything else. And then you go to the regulator. Regulator, yes, because otherwise you don't understand what you're doing, right? Excited to finish it off, Deepa, the question I ask everybody who comes on stage with me: you could have lunch or dinner with one person, dead or alive. Lunch or dinner with one person, dead or alive, who would you have lunch or dinner with? I did get asked on the previous panel. I said Newton, and I will stick with Newton. Isaac Newton. Yeah. But why is that? Why Isaac Newton, by the way? Why? It just...Something that creates the beginning of science in the minds of kids. Here we go. It's always good to have that. Listen, people think bring gravity back to Earth, but I guess Dubai always goes up, which is good on that perspective. Guys, thank you very much. Deepa Rajkharbon, Vice Chair of Vara. Thank you very much, everybody.