Last updated: 27/09/2025
Scintilla Network FZE (“Scintilla”) is a regulated Virtual Asset Service Provider (“VASP”) incorporated in Dubai, United Arab Emirates, and licensed by the Dubai Virtual Assets Regulatory Authority (VARA) to provide Broker-Dealer Services and Exchange Services.
Scintilla is committed to full transparency and compliance with the Virtual Assets and Related Activities Regulations 2023 and all relevant VARA Rulebooks.
When assessing any Virtual Asset for admission or trading, Scintilla considers:
• Market characteristics: market capitalization, liquidity, trading volume, and historical performance.
• Design and features: tokenomics, governance, and intended use cases.
• Regulatory treatment: classification and approvals from VARA and other regulators.
• Issuer background: experience, track record, and any history of fraud or regulatory action.
• Market integrity: potential for manipulation, wash trading, or fraud.
• Rights and obligations: enforceability of rights and verification of underlying assets, where applicable.
Scintilla also monitors Virtual Assets on an ongoing basis to ensure they remain suitable under these criteria.
Scintilla operates effective organisational and administrative arrangements to identify, monitor, and manage conflicts of interest.
• Conflicts are reviewed by the Board Risk & Compliance Committee.
• Material conflicts are disclosed to clients prior to engagement.
• Notifications are made to VARA where required.
Refer to Scintilla Conflicts of Interest Policy for more detail.
Scintilla maintains a whistleblowing framework to ensure concerns may be raised in confidence and without fear of retaliation.
• Whistleblowers are protected from dismissal or liability.
• Reports may include concerns regarding market conduct, AML/CFT, or misuse of assets.
• Relevant disclosures may be escalated to VARA or regulators where necessary.
Refer to Scintilla Whistleblowing Policy for more detail.
Scintilla is licensed by VARA to provide Broker-Dealer Services. Currently, Scintilla has not admitted any Virtual Assets for trading. Once live, we will disclose the following for each Virtual Asset:
• name, symbol, and issuance date;
• market capitalization, fully diluted value, and circulating supply;
• details of independent smart contract audits;
• largest historical price reduction (absolute and percentage terms);
• methodology for pricing quotations;
• order routing practices, including disclosure if 20% or more of orders are routed to
one liquidity source;
• statement confirming Scintilla does not hold client funds or provide clearing for other VASPs;
• custody arrangements ensuring segregation and reconciliation of client assets;
• details of referral arrangements and associated fees or benefits;
• confirmation that Scintilla only uses VARA-regulated custodians for custody.
Scintilla is licensed by VARA to provide Exchange Services. Currently, no Virtual Assets are admitted for trading. Once live, Scintilla will disclose the following for each Virtual Asset:
• name, symbol, and issuance details;
• market capitalization, fully diluted value, and circulating supply;
• details of independent smart contract audits;
• largest historical price reduction (absolute and percentage terms);
• pricing methodology applied on the venue;
• details of how deposited assets are safeguarded and how client ownership rights are protected.
Scintilla only partners with VARA-regulated custodians (e.g. HEX Trust) for the safekeeping of client Virtual Assets.
• Client assets are held in segregated wallets.
• Daily reconciliation is performed against client balances.
• Assets are never commingled with Scintilla’s proprietary holdings.
• Any discrepancies are reported immediately to VARA.
Scintilla applies strict privacy and data protection controls in line with the UAE PDPL and VARA Rulebooks.
• Personal data is collected only for lawful and regulatory purposes.
• AML/KYC data is retained for at least 8 years in line with VARA Rulebooks.
• Cross-border transfers are subject to PDPL safeguards.
• Breaches are reported promptly to the UAE Data Office and VARA.
Refer to Scintilla Privacy Policy for more detail.
Scintilla maintains a Client Complaints Policy to ensure concerns are handled fairly and transparently.
• Complaints acknowledged within 2 business days.
• Resolution or update provided within 30 calendar days.
• Clients may escalate unresolved complaints to VARA.
Refer to Scintilla Complaints Policy for more detail.
• Entity: Scintilla Network FZE, Dubai, UAE
• Professional License: L-2465
• Licenses: VARA Broker-Dealer Services and Exchange Services
o Tim Popplewell – tim@scintillanetwork.com
o Janey Schueller – janey@scintillanetwork.com
o contactus@scintillanetwork.com
• Custody partner: HEX Trust (VARA-regulated).
• Banking partner: Zand Bank (licensed by the UAE Central Bank).
• Referrals: any monetary or non-monetary benefits are disclosed.
• Governance: Scintilla’s Board and senior managers have no past convictions or prosecutions in the UAE or elsewhere.
• Market Conduct: Scintilla prohibits insider trading, manipulation, or abusive practices, in full compliance with VARA’s Market Conduct Rulebook.
For more information, please email: contactus@scintillanetwork.com
