Overview
Abu Dhabi Global Market is a financial free zone with its own legal system based on English common law, its own courts, and its own financial regulator, the FSRA.
That matters commercially. An institutional counterparty asked to face a UAE entity is usually more comfortable when the governing law and the courts are ones its own counsel already understands.
What it regulates
The FSRA has regulated virtual-asset activity since 2018, which makes it the longest-standing dedicated framework in the country.
- Accepted Virtual Assets — the assets a licensed firm may deal in, assessed against published criteria.
- Multilateral Trading Facilities for virtual assets, and custody.
- Broker-dealer and investment activities in virtual assets.
- Fund management, including funds with virtual-asset exposure.
- Fiat-referenced tokens, addressed by specific guidance.
- DLT Foundations, a vehicle for token projects, foundations and decentralised governance.
Who needs a permission
Any firm carrying on a regulated activity in or from ADGM. The instrument is a Financial Services Permission, and its scope is drawn narrowly: a firm does what its FSP says and nothing else.
Requirements
Capital. Category-based base capital and an expenditure-based requirement. The category is driven by the activities applied for.
Controlled functions. A Senior Executive Officer, Finance Officer, Compliance Officer and MLRO. The SEO must be resident in the UAE and be a real decision-maker.
Technology governance. Documented systems, custody and key management, resilience, and independent testing. For custody and MTF permissions this receives close attention.
Substance in ADGM. Premises and people on Al Maryah Island. This is not satisfied by a registered address.
Insurance. Professional indemnity proportionate to the permission.
Positioning against VARA and the DFSA
ADGM suits institutional exchanges, custodians, funds and foundation structures. The DIFC suits tokenised securities and wealth management. VARA suits businesses whose market is Dubai and whose counterparties are there.
The wrong reason to choose is that one sounds more prestigious. The right reasons are the counterparties, the governing law they expect, the activities each regulator will actually permit, and the cost of substance in each.
How we help
We scope the FSP to the activities the business needs and no more, prepare the regulatory business plan and financial projections, build the controlled function files, draft the technology and custody documentation the FSRA expects to see, and structure DLT Foundations where a token project needs a vehicle rather than a company.
- 01
Structuring
Activity mapping, regulator selection, group and holding structure.
Aún sin verificar
- 02
Entity incorporation
Trade name, initial approval, lease, corporate documents.
Aún sin verificar
- 03
Regulatory initial approval
Permission to incorporate and build. Not permission to operate.
Aún sin verificar
- 04
Policies and technology build
Rulebook-mapped policies, custody and key management, technology audits.
Aún sin verificar
- 05
MLRO appointment and goAML registration
Entity and officer registration, sanctions screening, reporting workflow.
Aún sin verificar
- 06
Bank or EMI onboarding
Frequently the longest single dependency, and outside the regulator control.
Aún sin verificar
- 07
Full licence
Operational permission granted.
Aún sin verificar
- 08
Ongoing supervision
Reporting, audits, filings, variation of permission.
Aún sin verificar
Tasas
Estos son los costes que un titular de licencia afronta realmente. Los importes quedan en blanco hasta que cada uno se haya cotejado con el arancel publicado por la autoridad: una cifra sin verificar es peor que ninguna.
Financial Services Permission application
Scales with the prudential category applied for.
Único
Aún sin verificar
Annual supervision fee
Anual
Aún sin verificar
ADGM commercial licence
Anual
Aún sin verificar
ADGM company registration
Único
Aún sin verificar
Data protection registration
Anual
Aún sin verificar
ADGM office
Anual
Aún sin verificar
Capital que debe mantenerse, no una tasa
Base capital requirement
Not a fee. Category-dependent.
Variable
Aún sin verificar
Documentos
Categorías indicativas. El expediente exacto depende de la actividad y el regulador puede pedir más.
- Passport copy, valid at least six months
- Passport photograph, white background
- Proof of residential address, dated within three months
- Curriculum vitae
- Bank or professional reference letter
- Police clearance or good conduct certificate — Se exige cadena de legalización
- Source of wealth and source of funds evidence
- UAE entry stamp or visa page
- Certificate of incorporation — Se exige cadena de legalización
- Memorandum and articles of association — Se exige cadena de legalización
- Certificate of incumbency or good standing — Se exige cadena de legalización
- Board resolution approving the UAE entity — Se exige cadena de legalización
- Register of members and directors
- Ultimate beneficial owner declaration
- Group structure chart to natural persons
- Audited financial statements, most recent two years
- Power of attorney for the UAE representative — Se exige cadena de legalización
- Business plan with three-year financial projections
- AML/CFT policy and procedures manual
- Enterprise-wide money laundering risk assessment
- MLRO appointment letter and fit-and-proper file
- Compliance monitoring programme
- Targeted financial sanctions screening procedure
- Governance map and senior management functions
- Outsourcing register and material outsourcing agreements
- Complaints handling and consumer protection policy
- Technology architecture and infrastructure description
- Custody and key management model
- Hot, warm and cold wallet policy
- Penetration test and vulnerability assessment report
- Business continuity and disaster recovery plan
- Cyber incident response plan
- Transaction monitoring and blockchain analytics arrangements
Interacción con otros reguladores
Preguntas frecuentes
What is an Accepted Virtual Asset?
ADGM does not let a licensed firm deal in whatever it likes. Assets are assessed against published criteria — maturity, liquidity, security, traceability and more — and a firm may only deal in those accepted for its permission. It is a meaningful constraint on product roadmaps.
Is ADGM better than VARA?
They answer different questions. ADGM suits institutional counterparties who want an English common-law system, its own courts and a long-established financial regulator. VARA suits businesses whose market is Dubai. Cost, timeline and counterparty expectations decide it, not prestige.
Can a DAO be a legal person in ADGM?
The DLT Foundations Regulations provide a vehicle designed for token projects and decentralised governance. It is a genuine legal person with its own constitution, which is a different proposition from an unincorporated association with a forum.
Fuentes
- ADGM Financial Services and Markets Regulations
- FSRA Guidance — Regulation of Virtual Asset Activities in ADGM — Framework in place since 2018; Accepted Virtual Assets concept
- ADGM DLT Foundations Regulations — Foundation vehicles for DAOs and token projects; year to be confirmed