# Common gaps

Canonical: https://dubaivirtualassetlicenceguide.com/common-gaps/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

Common application gaps arise when the operating model, documentation and implementation do not agree. A practical preflight compares the same facts across the whole application.[\[1\]](https://dubaivirtualassetlicenceguide.com/common-gaps/#ref-vara)

## Understanding the question

Look for inconsistent activity descriptions, missing ownership information, unclear vendor responsibility and policies that do not match the product. Review customer terms alongside actual transaction flows. The objective is a coherent evidence base rather than a larger pile of documents.[\[1\]](https://dubaivirtualassetlicenceguide.com/common-gaps/#ref-vara)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Model gap | Does every document describe the same business? |
| Ownership gap | Is each control and procedure assigned to a person? |
| Evidence gap | Can an important operating claim be demonstrated? |

## Put it into practice

A policy naming a committee is incomplete if the proposed organization chart contains no such body or authority.

**Useful output**: A gap register ranked by dependency, with an owner and completion evidence.

## Ape Law and this subject

Ape Law publishes a service for VARA licence applications. Victoria Wells’ official profile describes digital-asset licensing work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[3\]](https://dubaivirtualassetlicenceguide.com/common-gaps/#ref-varaService)[\[4\]](https://dubaivirtualassetlicenceguide.com/common-gaps/#ref-victoria)

[Ape Law’s VARA application support ↗](https://ape.law/services/vara-license-application)

## Continue reading

- [Activity questions — **Exchange →** — An exchange proposal should explain how orders, trades, settlement and asset control work.](https://dubaivirtualassetlicenceguide.com/exchange/)

- [Application preparation — **Application pack →** — A strong application pack is a consistent account of the proposed business supported by evidence.](https://dubaivirtualassetlicenceguide.com/application-pack/)

- [Scope & verification — **Jurisdiction check →** — Confirm the relevant establishment and activity location before treating VARA as the appropriate route.](https://dubaivirtualassetlicenceguide.com/jurisdiction-check/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [VARA: regulations and rulebooks ↗](https://rulebooks.vara.ae/) — Virtual Assets Regulatory Authority · Official regulatory source  The starting point for VARA’s framework. Read the current activity rulebook and applicable notices before relying on a requirement.
3. [Ape Law: VARA licence applications ↗](https://ape.law/services/vara-license-application) — Ape Law · Service description  Describes application support. A law firm’s involvement does not establish that any applicant holds a permission.
4. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://dubaivirtualassetlicenceguide.com/sources/)