In short: ADGM’s Board enacted the Financial Services and Markets (Amendment No. 1) Regulations 2026 on 19 May 2026, and the FSRA reissued its AML and Sanctions Rulebook (VER11) with them. The Regulations took effect on publication, 21 May 2026, the day VER11 was published, aligning ADGM with UAE Federal Decree by Law No. 10 of 2025.
Key facts
| Authority | Board of Directors of Abu Dhabi Global Market, acting under Article 6(1) of Law No. 4 of 2013 issued by His Highness the Ruler of the Emirate of Abu Dhabi (Regulations); Financial Services Regulatory Authority (Rules) |
|---|---|
| Instrument | Financial Services and Markets (Amendment No. 1) Regulations 2026, with FSRA amendments to the AML and Sanctions Rulebook (VER11), General Rulebook (VER14) and Glossary (VER28) |
| Issue date | Regulations enacted 19 May 2026; Regulations and Rules published 21 May 2026 |
| Effective date | 21 May 2026: the Regulations commence on publication (regulation 2(3)); the FSRA published VER11 the same day, and the version table closes VER10 on 20 May (our derivation of VER11’s start) |
| Applies to | Relevant Persons in ADGM: Authorised Persons (including banks), Recognised Bodies, DNFBPs and Non-Profit Organisations, as each chapter provides |
| Status | In force. No later AML amendment appears in ADGM’s 2026 notices |
| Official source | https://en.adgm.thomsonreuters.com/rulebook/21-may-amendments-fsra-regulations-enhancements-aml-framework |
| Last verified | 15 October 2026, against the ADGM Legal Framework site |
Why did ADGM make these changes?
The FSRA’s Consultation Paper No. 1 of 2026 (30 April 2026) sets out the purpose. Amendments were proposed “in light of the enactment of” Federal Decree by Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, which it calls the “New Federal AML Laws”. The review aimed to align FSMR and the Rulebook with them, reflect international best practice, refine the correspondent banking and electronic transfer rules, and improve clarity and usability.
The FSRA expected “minimal impact on existing compliance requirements”, because Federal AML Legislation already applies in ADGM, and “no substantive impact” on DNFBPs. It called the virtual asset transfer rules “of substance”, without more obligations than before.
How does the AML framework fit together?
What changed in the Regulations?
Meaning of money laundering (s 15A)
BEFOREA reference in “these Regulations” took in terrorist financing, unlawful-organisation financing and sanctions non-compliance.
NOWThe reading also covers the Rules and other subordinate legislation, and names proliferation financing.
Supervisory role (s 15A)
BEFOREThe FSRA supervised compliance with “relevant AML laws in the UAE”.
NOWThe FSRA supervises Relevant Persons’ compliance with Federal AML Legislation, except for Legal Professionals, where the UAE Ministry of Justice may delegate some powers to the FSRA or the Registrar of Companies.
DNFBP registration (ss 15C to 15E)
BEFOREThe prohibition and registration rules sat in AML Chapter 15 (consultation paper, para 7).
NOWFSMR bars DNFBP business in or from ADGM without registration, and covers suspension, withdrawal and delegation to the Registrar of Companies.
Definitions (s 258)
BEFOREFSMR defined DNFBP and listed the earlier federal texts.
NOWDNFBP takes its meaning from the Rules; the federal list names Decree by Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.
What changed in the Rulebook, and who does it reach?
Under Rule 1.2.1(2), Authorised Persons (other than Credit Rating Agencies) and Recognised Bodies follow Chapters 1 to 14, and DNFBPs follow Chapters 1 to 9 and 11 to 15. The columns apply that allocation to rules the consultation paper identified as updated (our reading).
| Rule | Requirement in VER11 | Banks and other Authorised Persons | DNFBPs |
|---|---|---|---|
| 4.1.1(2)(e), (g), (3)(b), (4) | Controls approved by Senior Management, with regular reporting to it; hiring screening; annual review that takes in the business risk assessment | Applies | Applies |
| 6.1.1(a), 6.1.3 | Business risk assessment approved by Senior Management and kept up to date on an ongoing basis | Applies | Applies |
| 10.1.1(e) | Senior Management approval before a Correspondent Banking relationship is established | Applies | No |
| 10.3.4(2) | Virtual asset transfers: transfer information need not be verified where the originator’s daily aggregate is under USD 1,000 and nothing is suspicious | Applies | No |
| 12.1.1 | MLRO appointed with the Regulator’s approval and resident in the UAE | Applies | Applies |
| FSMR 15C | Registration with the Regulator to carry on DNFBP business in or from ADGM | No | Applies |
From when?
- 30 April 2026Consultation Paper No. 1 issued
- 14 May 2026Comments closed
- 19 May 2026Board enacted the Regulations
- 21 May 2026Regulations and Rules published; in force
- 16 September 2026GEN and GLO reissued (funds notice); AML and FSMR unchanged
What should banks and MLROs do?
Our suggestions, not requirements of the instruments:
- Check that senior management has approved the controls (Rule 4.1.1(2)(e)) and the business risk assessment (6.1.1(a)), and that the annual review (4.1.1(4)) refers to it.
- For correspondent or virtual asset flows, re-read Rules 10.1 and 10.3, including unhosted wallets (10.3.6).
- Update legal references to Decree by Law No. 10 of 2025; confirm the MLRO’s approval and UAE residency (12.1.1).
What to watch for: the consultation paper (para 9) foreshadows possible cash-dealing limits for DNFBPs under ADGM commercial legislation, to be consulted on by the Registration Authority.
Frequently asked questions
Is the ADGM AML framework amendment in force?
Yes. The Regulations took effect on publication, 21 May 2026 (regulation 2(3)), and the FSRA published AML VER11 the same day (the version table closes VER10 on 20 May). No later AML amendment appears in ADGM’s 2026 notices.
Why did ADGM amend its AML framework?
The consultation paper ties the review to Federal Decree by Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, international best practice and a clearer Rulebook.
Do banks in ADGM face new obligations?
The FSRA expected “minimal impact on existing compliance requirements”, since Federal AML Legislation already applies in ADGM. Chapters 4, 6, 10 and 12 are among those updated for Authorised Persons.
Who supervises AML in ADGM, and who registers DNFBPs?
Section 15A designates the FSRA as Supervisory Authority for Federal AML Legislation and gives it supervision of Relevant Persons except Legal Professionals. Sections 15C to 15E place DNFBP registration with the FSRA, which may delegate it to the Registrar of Companies.
Sources (official, verified 15 October 2026)
- ADGM Notice, 21 May 2026: Amendments to FSRA Regulations (Enhancements to AML Framework) https://en.adgm.thomsonreuters.com/rulebook/21-may-amendments-fsra-regulations-enhancements-aml-framework
- ADGM Notice, 21 May 2026: FSRA Rules (Enhancements to AML Framework) https://en.adgm.thomsonreuters.com/rulebook/21-may-fsra-rules-enhancements-aml-framework
- FSMR (Amendment No. 1) Regulations 2026 (PDF) https://en.adgm.thomsonreuters.com/sites/default/files/net_file_store/Financial_Services_and_Markets_(Amendment_No._1)_Regulations_2026.pdf
- FSMR 2015, consolidated to 21 May 2026 (PDF) https://en.adgm.thomsonreuters.com/sites/default/files/net_file_store/ADGM1547_12483_VER29210526.pdf
- Anti-Money Laundering and Sanctions Rulebook, VER11.210526 (PDF) https://en.adgm.thomsonreuters.com/sites/default/files/net_file_store/AML_VER11.210526.pdf
- AML Rulebook version history https://en.adgm.thomsonreuters.com/rulebook/anti-money-laundering-and-sanctions-rulebook-aml
- Consultation Paper No. 1 of 2026 (page) https://en.adgm.thomsonreuters.com/rulebook/consultation-paper-no-1-2026-proposed-enhancements-anti-money-laundering-framework-fsra
- Consultation Paper No. 1 of 2026 (PDF) https://en.adgm.thomsonreuters.com/sites/default/files/net_file_store/Consultation_Paper_No._1_of_2026_-_Proposed_Enhancements_to_the_Anti-Money_Laundering_Framework_of_the_FSRA_.pdf
- UAE
- ADGM
- FSRA
- AML/CFT
- FSMR
- AML Rulebook
- DNFBP
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