Crypto License in Abu Dhabi (ADGM)

Trading platforms providing order matching and price discovery for Accepted Virtual Assets can operate within the MTF framework.

OTC businesses may operate under dealing and/or arranging permissions depending on whether the firm acts as principal, agent or facilitator.

Businesses executing or arranging client transactions can be structured under the relevant intermediary-type regulated activities.

Businesses buying or selling Virtual Assets as principal or agent may operate under the appropriate dealing permission.

Businesses safeguarding Accepted Virtual Assets for clients may operate as Virtual Asset Custodians.

Asset managers may manage portfolios involving Virtual Assets under the relevant asset management permission.

Businesses providing regulated advice in relation to Virtual Assets may seek the relevant advisory permission.

Businesses combining several services may seek an FSP covering multiple regulated activities, subject to the applicable requirements.

The applicant may be required to incorporate or register an appropriate legal entity in ADGM as part of the authorisation process.

The applicant must obtain the relevant Commercial Licence from the ADGM Registration Authority before final FSP authorisation.

The applicant must secure appropriate premises in ADGM as part of satisfying the applicable In-Principle Approval pre-conditions.

The FSRA expects the firm’s “mind and management” to be located within ADGM.

Sufficient resources must be maintained in ADGM across functions relevant to the business, which may include commercial, governance, and compliance.

The ownership and control structure should be transparent and capable of satisfying the FSRA’s due diligence requirements.

The governance structure must be suitable for the nature, complexity and risk profile of the proposed regulated activities.

The applicant must have appropriate senior management and key appointment holders who satisfy the applicable FSRA requirements.

Following In-Principle Approval, the applicant may need to open bank accounts and capitalise the entity before final authorisation.

The local structure must support the firm’s actual operations and be capable of satisfying any applicable testing and verification.

The applicant must appoint a Senior Executive Officer who satisfies the applicable FSRA requirements and is resident in the UAE.

Individuals performing the Licensed Director controlled function must obtain Approved Person status and satisfy the applicable fitness and probity requirements.

The firm must appoint a Finance Officer responsible for applicable financial management and regulatory reporting functions.

The firm must appoint a Compliance Officer. The Compliance Officer must be resident in the UAE unless the FSRA grants an applicable waiver.

The firm must appoint an MLRO with appropriate seniority, experience and independence. The MLRO must be resident in the UAE.

The business must maintain risk-based AML/CFT, customer due diligence, KYC and transaction monitoring arrangements appropriate to its activities.

Authorised Persons must maintain controls capable of identifying and managing applicable sanctions risks.

Virtual Asset firms must maintain sufficient technical and IT expertise to support technology governance, security and operational resilience.

Systems, wallets, private keys, security controls, risk management, recovery and business continuity arrangements must be sufficiently robust.

Where the firm holds or controls client money or other client assets, applicable FSRA safeguarding and protection requirements must be met.

The firm must maintain the financial, prudential and other regulatory reporting capabilities applicable to its FSP.

The FSRA expects substantive resources within ADGM across functions relevant to the business, with the firm’s “mind and management” in ADGM.

The applicant must submit the GIRA Form and the Virtual Assets Application (VAS) Form, together with relevant activity-specific forms.

The application must include a detailed launch plan covering the stages from application through In-Principle Approval, FSP issuance and operational launch.

The applicant must provide the corporate and ownership information required for the FSRA to assess the proposed structure and relevant controllers.

Applicable Approved Person Status forms must be submitted for individuals proposed to perform relevant controlled functions.

The application must demonstrate the applicant’s ability to satisfy the financial resources and prudential requirements applicable to its activities.

The applicant must demonstrate appropriate AML/CFT, sanctions, compliance and risk-management systems and controls.

Virtual Asset applicants must demonstrate appropriate technology governance and controls relating to wallets, private keys, security, risk management and systems.

Additional supporting documents, policies, procedures and operational materials may be required depending on the activities included in the FSP.

There is no single minimum capital figure applicable to every ADGM Virtual Asset firm; the requirement depends on the regulated activities.

Base capital requirements may range from approximately USD 10,000 to USD 2 million depending on the applicable regulated activities.

A Virtual Asset Custodian must maintain the higher of USD 250,000 or six months’ Annual Audited Expenditure.

An MTF operator must maintain regulatory capital equal to six months’ operational expenses, together with an additional buffer.

Regulatory capital applicable to a Multilateral Trading Facility must be maintained in fiat form.

The FSRA applies the application fees associated with the underlying regulated activities included in the proposed FSP.

The Virtual Asset add-on application fee is generally USD 20,000 for Virtual Asset regulated activities.

Where the FSP includes Operating a Multilateral Trading Facility in relation to Virtual Assets, the applicable Virtual Asset application fee is generally USD 125,000.

The Virtual Asset annual supervision fee is generally USD 15,000 for each regulated activity, while an MTF is subject to a USD 60,000 fee.

A Multilateral Trading Facility using Virtual Assets is additionally subject to an FSRA trading levy calculated on a sliding-scale basis.

The applicant contacts the FSRA Authorisation team for an initial discussion about the proposed business and Virtual Asset activities.

The FSRA holds an initial meeting to assess the business model and regulatory requirements, explain the relevant activities and outline the process.

The FSRA reviews the draft regulatory business plan and determines whether the proposed application can proceed, providing feedback.

The applicant submits the completed application forms, supporting documentation and applicable application fees.

The FSRA reviews the application, addresses outstanding matters and may conduct interviews with proposed Approved Persons.

If the application is successful, the FSRA issues an In-Principle Approval setting out the pre-conditions that must be satisfied before final authorisation.

The applicant completes the applicable conditions, including the Commercial Licence, premises, banking and capitalisation.

Once the pre-conditions are satisfied, the FSRA may grant the FSP. Operations may begin only after any required testing or third-party verification.

The authorisation period is assessed case by case rather than through one universal statutory processing period.

Virtual Asset applicants should expect substantive discussions with the FSRA before a formal application is accepted.

A complete regulatory business plan, application package and technology framework can reduce delays during assessment.

MTF, custody, multiple regulated activities and complex technology arrangements generally require more extensive regulatory review.

Timing depends on regulatory review, responses to information requests and the availability and preparedness of proposed Approved Persons.

After IPA, the applicant must complete entity setup, premises, staffing, banking and capitalisation before final authorisation.

Where launch testing or third-party system verification is required, the applicant must complete these steps before commencing operations.

The overall duration depends heavily on how quickly the applicant can satisfy regulatory, operational, staffing, technology and establishment requirements.

UAE Corporate Tax generally applies at 0% on taxable income up to AED 375,000 and 9% above that threshold. Different rules may apply to Free Zone Persons.

The standard UAE VAT rate is 5%. The VAT treatment of Virtual Assets and related services depends on the nature of the transaction.

Authorised Persons must pay the applicable annual FSRA supervision fees associated with their regulated activities and Virtual Asset permissions.

The firm must maintain appropriate AML/CFT, customer due diligence, KYC, transaction monitoring and sanctions controls.

Authorised Persons must submit the financial, prudential and other regulatory information applicable to their FSP on an ongoing basis.

The business must continue satisfying the capital and financial resource requirements applicable to its regulated activities.

Where the firm holds or controls client money or other client assets, applicable FSRA safeguarding and protection requirements must be met.

Authorised Persons must maintain appropriate cyber risk management and technology governance and comply with applicable rules.

The firm must maintain appropriate systems recovery, resilience and business continuity arrangements proportionate to its activities.

Applicable FSRA notification and approval requirements must be followed when material changes are made to the business.

Depending on classification and activities, an ADGM entity may be subject to applicable international tax reporting requirements.

The company must continue operating within the scope and conditions of its FSP and the applicable FSRA Rulebooks.

The business model must be mapped carefully against the Virtual Asset regulated activities because the FSP scope determines the requirements.

The ownership and control structure must be transparent and capable of satisfying the FSRA’s due diligence requirements.

Proposed senior management and Approved Persons should have sufficient knowledge, experience, authority and availability for their roles.

The applicant must identify and be capable of meeting the prudential capital requirements applicable to its proposed activities.

The business needs a risk-based AML/CFT framework addressing customer due diligence, transaction monitoring, sanctions and Virtual Asset risks.

Systems, wallets, private keys, cybersecurity, transaction monitoring and business continuity arrangements must be sufficiently developed.

The applicant should identify where clients will be located and assess whether additional authorisations are required outside ADGM.

The FSRA expects substantive resources and the firm’s “mind and management” to be located within ADGM.

Final launch may depend on successful operational testing or third-party verification of systems to the FSRA’s satisfaction.

Multi-activity, MTF, custody and complex technology models may involve materially higher regulatory, capital, staffing, technology and compliance costs.