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.
Virtual Asset Standards
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.
Conflicts of Interest
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.
See our [Conflicts of Interest Policy] for more detail.
Whistleblowing
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.
See our [Whistleblowing Policy] for more detail.
Broker-Dealer Services
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 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.
Exchange Services
Scintilla is licensed by VARA to provide Exchange Services.
Currently, no Virtual Assets are admitted for trading. Once live, Scintilla will disclose 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.
Custody and Asset Protection
Scintilla partners only 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.
Data Privacy
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 AML requirements.
- Cross-border transfers are subject to PDPL safeguards.
- Breaches are reported promptly to the UAE Data Office and VARA.
See our [Privacy Policy] for more detail.
Client Complaints
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.
See our [Complaints Policy] for more detail.
Corporate Information
- Entity: Scintilla Network FZE, Dubai, UAE
- Professional License: L-2465
- Licenses: Broker-Dealer Services, Exchange Services (VARA)
- Tim Popplewell – tim@scintillanetwork.com
- Janey Schueller – janey@scintillanetwork.com
- MLRO – mlro@scintillanetwork.com
- DPO – privacy@scintillanetwork.com
Other Disclosures
- 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 alignment with the VARA Market Conduct Rulebook.
11. Contact Us
For more information, please contact:
Contactus@scintillanetwork.com
