The Riffle
The Abu Dhabi Global Market (ADGM) Financial Services Regulatory Authority (FSRA) has finalised a series of amendments to its anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions framework. Effective from May 2026, the changes update both the Financial Services and Markets Regulations 2015 (FSMR) and the AML Rulebook.
The amendments are designed to align the ADGM framework with recent UAE federal legislation, including Federal Decree Law No. (10) of 2025, while reinforcing international standards promoted by the Financial Action Task Force (FATF).
While many of the requirements will already be familiar to regulated firms, the updates place greater emphasis on governance accountability, risk-based compliance, record-keeping obligations, sanctions controls, and the treatment of virtual asset activities.
Key Highlights
Closer alignment with UAE federal legislation through the incorporation of recent AML and proliferation financing laws and executive regulations.
Greater accountability for boards and senior management, with responsibility for AML compliance explicitly resting with governing bodies and senior leadership.
Reinforced risk-based approach (RBA) requiring firms to continuously assess and manage risks relating to customers, products, jurisdictions, delivery channels, and emerging technologies.
Enhanced operational expectations, including maintaining AML records for at least six years and ensuring records can be provided to the regulator promptly when requested.
Continued focus on suspicious activity reporting, including the obligation to report suspicious activities through the UAE’s goAML platform.
Specific requirements for Virtual Asset Service Providers (VASPs), which must be appropriately authorised or recognised by the FSRA.
Additional scrutiny of high-risk jurisdictions, with differentiated treatment for jurisdictions subject to FATF Calls for Action and those under Increased Monitoring.
Ongoing emphasis on sanctions compliance, including adherence to UAE, UN Security Council, and relevant international sanctions measures.
Why It Matters
The latest amendments continue the FSRA’s shift towards a more governance-led and risk-focused approach to financial crime compliance.
For regulated firms, AML compliance is increasingly being viewed as a board-level responsibility rather than a function delegated solely to compliance teams or MLROs. Senior management will be expected to demonstrate active oversight of financial crime risks and ensure that controls remain proportionate to the firm’s risk profile.
The changes are also significant for firms operating in higher-risk sectors, including virtual assets and cross-border financial services, where regulators continue to focus on customer due diligence, sanctions screening, transaction monitoring, and jurisdictional risk assessments.
More broadly, the amendments reflect the UAE’s continued efforts to strengthen its financial crime framework and maintain alignment with international regulatory expectations.
Conclusion
The FSRA’s AML framework enhancements do not fundamentally alter the direction of travel for regulated firms, but they do reinforce the regulator’s expectations around governance, risk management, and operational effectiveness.
Firms operating within ADGM should consider reviewing their AML policies, risk assessments, governance arrangements, reporting procedures, and sanctions controls to ensure they remain aligned with the updated framework and evolving regulatory expectations.
