“It’s not something that’s prescriptive, because you do need, in this industry, to be slightly flexible, insofar as it’s a fast-paced, fast-moving industry. So if you’re very prescriptive in nature, you could probably expect it to be something that was out of date as soon as you wrote it,” Swartz said, adding that DLA Piper worked on the package for nine months, and had been tracking Dubai’s regulation of the sector even before formally engaging with VARA.



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