What happened

On 11 August 2026, Coinbase received a Financial Services Permission (FSP) from the FSRA to establish its international tokenization hub in ADGM, authorising it to arrange investment deals and provide custody services to facilitate the issuance and registration of tokenized securities. The tokens are fully backed by underlying shares, with token holders receiving full shareholder rights including dividends and voting rights, and the arrangement embeds ongoing sanctions screening with asset-freezing capability at wallet level.

Why it matters

The permission extends ADGM's virtual asset framework — one of the world's first, dating to 2018 — into large-scale tokenized securities issuance by a major global exchange, reinforcing Abu Dhabi's position as a hub for regulated, blockchain-enabled capital markets infrastructure.

What firms should do

• Firms considering tokenized securities offerings should review Coinbase's FSP as a benchmark for the custody and arranging permissions required, and the sanctions-screening/asset-freeze functionality regulators expect embedded at wallet level.
• Custodians and broker-dealers should assess whether their own token infrastructure supports equivalent shareholder-rights pass-through, including dividends and voting, for tokenized securities.
• Monitor FSRA's continued expansion of its virtual asset regime as further large-scale institutional players enter the market.

What happened

On 13 August 2026, the Security Council Committee pursuant to resolutions 1267 (1999), 1989 (2011) and 2253 (2015) amended four entries on its ISIL (Da’esh) and Al-Qaida Sanctions List: updating the aliases and listing history of Mohammed Salahaldin Abd El Halim Zidane, a.k.a. Sayf Al-Adl (QDi.001); adding an updated address for Adem Yilmaz (QDi.261); updating identification numbers for Shafi Sultan Mohammed Sultan Al-Ajmi (QDi.338); and updating the listing history of the entity Ummah Tameer E-Nau (UTN) (QDe.068).

Why it matters

The amendments refresh aliases, addresses and identifiers on entries that in some cases have stood since 2001 — a reminder that long-standing sanctions entries are still actively maintained, and that screening against outdated alias or address data can cause a true match to be missed.

What firms should do

• Update screening records for QDi.001, QDi.261, QDi.338 and QDe.068 to capture the newly added aliases, addresses and identification numbers.
• Re-run screening against the amended entries to check whether any historical or dormant partial matches now resolve differently.
• Confirm screening tools draw from the current ISIL (Da’esh) and Al-Qaida Sanctions List rather than a cached or partial extract.

What happened

On 14 August 2026, the FSRA and the UAE's General Commercial Gaming Regulatory Authority (GCGRA) signed a Memorandum of Understanding formalising a framework for regulatory cooperation, covering supervisory coordination, policy dialogue, investigative assistance and regulatory information sharing within applicable confidentiality and legal requirements.

Why it matters

The MoU creates a formal channel between ADGM's financial regulator and the UAE's federal gaming regulator as the commercial gaming sector expands and increasingly interacts with regulated financial services such as payments and custody, supporting coordinated supervision and greater regulatory certainty for market participants operating across both perimeters.

What firms should do

• Firms operating at the intersection of financial services and commercial gaming — payments, e-wallets or custody arrangements serving gaming operators — should expect closer information-sharing between FSRA and GCGRA and review cross-sector disclosures accordingly.
• Where a group entity holds or is applying for both an FSRA licence and a GCGRA authorisation, ensure consistent representations are made to both regulators given the new cooperation channel.
• Monitor for further joint guidance or supervisory statements as the FSRA/GCGRA cooperation framework is operationalised.

What happened

On 14 August 2026, the Committee amended four further entries: updating the place of birth, address and listing history of Amin Muhammad Ul Haq Saam Khan (QDi.002); adding an alias for Abubakar Swalleh (QDi.436), an ISIL facilitator providing financial and logistic support in East and Southern Africa; updating the listing history of Hamida Nabaggala (QDi.439); and updating the listing history of the entity Islamic State in Iraq and the Levant – Khorasan (ISIL-K) (QDe.161).

Why it matters

The entries span individuals linked to core Al-Qaida leadership through to regional ISIL financing and facilitation networks in Central, East and Southern Africa, and the ISIL-K affiliate in South Asia — illustrating the geographic breadth firms must screen across, not just entries tied to their core markets.

What firms should do

• Update screening records for QDi.002, QDi.436, QDi.439 and QDe.161 with the amended particulars.
• Pay particular attention to Abubakar Swalleh (QDi.436) and Hamida Nabaggala (QDi.439), both linked to ISIL financing networks in Central, East and Southern Africa, given the elevated regional facilitation risk.
• Ensure screening captures ISIL-K (QDe.161) under all listed aliases, given its use of multiple naming conventions across sources.

What happened

On 18 August 2026, the Committee amended 21 entries on its ISIL (Da’esh) and Al-Qaida Sanctions List — the largest set of amendments in the month. The revisions cover senior Jemaah Islamiyah figures (including Hambali, QDi.087), Abu Sayyaf Group members, Al-Qaida in the Islamic Maghreb (AQIM) leadership, and long-standing entities including Al-Qaida in the Arabian Peninsula (AQAP, QDe.129) and the Islamic Jihad Group (QDe.119), primarily updating listing histories, confirmed-deceased status, and address or alias details.

Why it matters

With 21 entries revised in a single update — including confirmed-deceased status changes and an updated leadership designation for AQAP — this is a significant refresh of some of the sanctions list’s longest-standing entries.

What firms should do

• Refresh screening data in full against the 18 August amendments rather than applying incremental patches, given the scale of this update.
• Review any historical matches or hits against the amended individuals and entities for current status, including confirmed-deceased designations.
• Note the updated leadership designation for Al-Qaida in the Arabian Peninsula (AQAP, QDe.129) and update any related-party screening accordingly.

What happened

On 27 August 2026, the Security Council Committee established pursuant to resolution 1988 (2011) amended the entry for Abdul Salam Hanafi Ali Mardan Qul (TAi.027), a former Deputy Minister of Education under the Taliban regime, updating his passport details.

Why it matters

Continued amendments to senior Taliban-linked entries on the 1988 List reflect the Committee’s ongoing efforts to keep travel and identity data current for high-profile designated individuals with cross-border movement — relevant to firms with any Afghanistan-linked client exposure.

What firms should do

• Update screening records for TAi.027 (Abdul Salam Hanafi) with the newly added passport identifier.
• Re-screen any Afghanistan-linked clients, counterparties or correspondent relationships against the amended 1988 (Afghanistan/Taliban) Sanctions List.
• Confirm screening tools pull the 1988 List alongside the ISIL/Al-Qaida list, since both feed into the UN Consolidated List firms are expected to screen against.

What happened

The Registration Authority now requires public disclosure of nominee status for shareholders and directors, granting the Registrar express powers to obtain beneficial ownership information for trusts, restricting cash payments above prescribed thresholds for DNFPBs, and extending beneficial ownership requirements to registered branches of foreign entities.

Why it matters

These targeted amendments strengthen ADGM's beneficial ownership transparency and AML/CFT framework in line with international standards and take effect immediately upon publication — with direct implications for corporate structuring, nominee arrangements, and cash-handling practices.

What firms should do

• Review shareholder and director registers to ensure nominee status is accurately disclosed.
• Trusts connected to ADGM should be prepared to provide beneficial ownership information to the Registrar on request.
• Legal, accounting, company service, and real estate businesses should review cash acceptance policies against new thresholds.
• Branches of foreign legal persons should confirm they can maintain and produce beneficial ownership information on their foreign parent.

What happened

FSRA issued 95 Financial Services Permissions and 120 In-Principle Approvals in 2025, up 22% and 32% year-on-year respectively and signed 5 new international MoUs. The report highlights continued investment in RegTech and SupTech to support data-driven, efficient supervision as ADGM's ecosystem grows in scale and sophistication.

Why it matters

Strong growth in authorisations signals deepening confidence in ADGM as a financial centre, but it also means the FSRA is scaling up its supervisory technology and international cooperation — firms should expect more data-driven, intensive oversight as the regulated population expands.

What firms should do

• Review the Annual Report's supervisory priorities and benchmark your firm's compliance posture accordingly.
• Prepare for increased use of RegTech/SupTech-driven supervision, including more data-intensive reporting expectations.
• New entrants and applicants should factor in the growing volume of Financial Services Permissions and In-Principle Approvals when planning authorisation timelines.

What happened

FCCP reminded all Relevant Persons of their obligations to establish AML/CFT systems and controls, complete two-stage registration on the FIU's goAML platform, and submit the correct report type — including STRs, SARs, REARs, and time-bound reports such as PNMRs (5 business days), CNMRs (24-hour asset freeze), and HRCA/HRC reports (3 business days before engagement or transaction).

Why it matters

Reporting deadlines under the goAML framework are strict and time-critical, particularly for name-match and high-risk jurisdiction reports and FSRA has confirmed it will take enforcement action against firms that fail to comply with these AML/TFS obligations.

What firms should do

• Confirm your entity and MLRO/deputy MLRO are fully registered on goAML (both SACM pre-registration and portal registration stages).
• Map internal escalation processes against each report type and its specific trigger and deadline, especially PNMR, CNMR, HRCA, and HRC.
• Ensure annual AML risk assessments, red flag registers, and training are up to date and tailored to your business.
• Maintain STR/SAR records for the required six-year retention period and notify FCCP by email upon submission.

What happened

The Takeover Panel enacted the first comprehensive Takeover Code under the Takeover Regulations 2015, covering approach and announcement requirements, independent advice, offer terms and conduct, profit forecasts, asset valuations, offer timetables, restrictions following offers, and schemes of arrangement. The Rules took effect immediately on publication.

Why it matters

This is ADGM's first detailed takeover rulebook, giving the Panel clear enforcement powers — including compensation rulings, private and public censure, and referral to other regulators — for breaches during M&A activity involving ADGM-incorporated public companies.

What firms should do

• Listed and public companies incorporated in ADGM should review the new Code against any live or anticipated takeover situations.
• Boards and advisers should familiarise themselves with the announcement, offer document, and conduct-during-offer requirements before engaging in takeover activity.
• Ensure profit forecasts, asset valuations, and offer timetables are prepared in line with the new Code's specific requirements.
• Build in Panel consultation early where a transaction may trigger dual jurisdiction with another regulator.

What happened

FSRA issued Consultation Paper No. 2 of 2026, proposing to limit mandatory Court sanctioning under Part 7 of FSMR to insurance business transfers only, excluding intragroup transfers with full policyholder consent and reinsurance transfers with cedant consent. All other Transfer Schemes — including banking and non-insurance transfers — could instead proceed as a “Modified Transfer Scheme” under proposed GEN Chapter 8A: advance FSRA notice, direct client notice and public notice, with Banks and the two exclusions also needing FSRA no-objection. Comments close 21 September 2026.

Why it matters

This changes who needs Court sanctioning at all — today every transfer does; under the proposal only insurance transfers (barring the two exclusions) still will. Most transfers currently seen in ADGM, including by Banks, would gain a faster, lower-cost route, while notice requirements and an FSRA no-objection preserve client protection.

What firms should do

• Assess whether a planned transfer, restructuring or intragroup reorganisation would qualify as a Modified Transfer Scheme under proposed GEN Chapter 8A.
• Insurers/reinsurers: check whether your transfer falls within the two exclusions — if not, mandatory Court sanctioning still applies.
• Banks: note the added requirement to obtain FSRA no-objection even under the modified route.
• Submit responses to CP2 of 2026 to fsra.consultation@adgm.com by 21 September 2026.

What happened

The Registration Authority (RA) activated its Broker Classification Framework for real estate brokers in ADGM, recognising high performers against transaction activity, continuous professional development and customer feedback. The RA will run workshops with brokerages to support the framework and guide further development.

Why it matters

This applies to real estate brokers and brokerages in ADGM specifically, not financial services firms generally. It creates a criteria-based recognition mechanism tying a broker's standing to activity, CPD and client feedback — raising the bar on demonstrable professionalism and giving buyers, sellers, owners and tenants a visible quality signal.

What firms should do

• Review the classification criteria — transaction activity, CPD and customer feedback — and assess your standing against them.
• Keep CPD records and transaction history ready for the RA's assessment.
• Strengthen customer feedback capture, since feedback now feeds directly into classification.
• Attend RA workshops and engagement sessions to stay ahead of further guidance.

What happened

Four UN sanctions committees updated their lists in July: on 9 July, ISIL (Da’esh)/Al-Qaida amended the entry for Hamidah Nabaggala (QDi.439); on 17 July, the 1533 Committee added six individuals and two entities linked to AFC, M23, FDLR, ADF and Twirwaneho in the DRC; on 24 July, the Libya Committee added the vessel Avax (IMO 9058713) for illicit petroleum exports; and on 31 July, the 1988 Committee amended five Afghanistan/Taliban entries, including Sirajuddin Haqqani's identity and passport details.

Why it matters

Four sanctions regimes changed in one month — Afghanistan, Libya, the DRC and ISIL/Al-Qaida — a reminder that screening must cover every relevant regime, not just those tied to a firm's core markets.

What firms should do

• Update screening against all four list changes: 1988 (Afghanistan/Taliban), Libya, 1533 (DRC), and ISIL/Al-Qaida.
• Re-screen clients, counterparties and any vessel/entity exposure against the amended and added entries.
• Confirm screening tools pull from the UN Consolidated List, not a single regime in isolation.
• Record the screening date, method and outcome as FSRA AML/CFT compliance evidence.

What happened

FSRA's FCCPD issued Notice No. FSRA/FCCP/96/2026, reminding all ADGM RPs, including FIs, VASPs and DNFBPs, of their obligations under UAEFIU Regulation No. (1) of 2026 on the Postponement or Suspension of Suspicious Transactions and Freezing of Funds, issued under Federal Decree-Law No. (10) of 2025 on AML/CFT/CPF and Cabinet Decision No. (134) of 2025. The notice should be read with FCCP Notice 83 of 2026 (the IEMS User Guide).

Why it matters

Timely, accurate compliance with UAEFIU reporting obligations, Suspension Orders, Freezing Orders and Monitoring Orders underpins the UAE's AML/CFT/CPF framework and helps prevent the dissipation of suspected criminal proceeds. FSRA has confirmed it will take appropriate action against RPs for contraventions of applicable legislation.

What firms should do

• Review and, where necessary, update policies, procedures, systems and governance arrangements to ensure compliance with the UAE FIU Regulation.
• Ensure MLROs and compliance teams are familiar with IEMS and the procedures for urgent reporting of suspicions and implementing Suspension, Freezing and Monitoring Orders (see FCCP Notice 83 of 2026).
• Access and review the full UAEFIU Regulation via the link published on the FCCP website, referenced in the notice.

What happened

FATF concluded its final Plenary under the Mexican Presidency: added Bosnia and Herzegovina and Iraq to the grey list, removed Algeria and Namibia, adopted Canada/Türkiye evaluations, and approved new work on payment transparency and virtual assets.

Why it matters

Grey list changes directly affect DIFC firms' due diligence and risk-rating for counterparties linked to the newly listed or delisted jurisdictions. The broader initiatives on payment transparency and virtual assets signal future AML/CFT expectations.

What firms should do

• Update due diligence and risk ratings for Bosnia and Herzegovina, Iraq, Algeria, and Namibia.
• Monitor forthcoming FATF publications on payment transparency (Recommendation 16), virtual assets/VASPs, and decentralised finance for relevance to product offerings.
• Brief compliance/MLRO teams on the UK Presidency's fraud-focused priorities.

What happened

FSRA's FCCPD issued Notice No. FSRA/FCCP/107/2026 to SEOs, MLROs and Principal Representatives of RPs. Pursuant to Notice No. FSRA/FCCP/165/2025, it reiterates the need for ADGM RPs to maintain effective systems and controls to identify, assess, manage and mitigate exposure to unlicensed VASP activity.

Why it matters

Unlicensed virtual asset (VA) activity conducted or facilitated through an ADGM firm's relationships, products, services, delivery channels or transactions creates direct regulatory and reputational exposure. FSRA expects RPs to remain vigilant, including against false claims of association with ADGM or licensing by FSRA.

What firms should do

• Confirm no unlicensed VA activity is conducted or facilitated through any relationship, product, service, channel or transaction without proper licensing.
• Embed controls, with effective oversight and clear escalation/investigation processes, to detect exposure to unlicensed VASPs.
• Notify FSRA via the Complaints portal (and other competent authorities where applicable) upon identifying or suspecting unlicensed VA activity, including false claims of ADGM/FSRA association or licensing.

What happened

On 4 Jun 2026 ADGM Board enacted, and on 26 Jun published, amendments to the Administrative, Beneficial Ownership, Commercial Licensing, Companies and DLT Foundations Regulations, plus two new rulebooks: CLR Conditions of Licence and Branch Registration Rules 2026(A) and LLP Rules 2026 (replacing LLP Rules 2025(A)). Key changes: a "supplementary operating address" option; Court-enforced trustee beneficial ownership disclosure; nominee director/shareholder filing duties; registered email as formal address for service; and a new CLR false statement offence.

Why it matters

These changes affect nearly every ADGM entity: new address, beneficial ownership, nominee disclosure and LLP governance rules mean updated filings and controls are needed.

What firms should do

• Review the Registrar's supplementary operating address policy and assess if existing/planned premises qualify instead of a branch.
• Trustees with any ADGM connection should prepare to respond to Registrar information requests identifying the beneficial owners of a trust.
• Update company filings and registers to capture new director and nominee shareholder/director statements, and registered email address particulars where relevant.
• Review LLP governance documents, agreements and filings against the new LLP Rules 2026.

What happened

UAE published its Proliferation Financing (PF) NRA 2026, identifying PF as a medium-high national risk, driven by sanctions evasion linked to high-risk jurisdictions (e.g. DPRK and Iran), with exposure arising from trade finance, virtual assets, and complex ownership structures.

Why it matters

The NRA highlights increased expectations on firms to identify, assess, and mitigate proliferation financing risks, particularly in trade finance and virtual asset activities, aligning with UAE national priorities and sanctions compliance obligations.

What firms should do

• Update enterprise risk assessments to incorporate PF risks.
• Enhance screening and monitoring for sanctions evasion typologies.
• Strengthen due diligence on ownership structures and high-risk jurisdictions.
• Review exposure to VASPs, trade finance, and cross-border transactions.

What happened

FSRA issued Notice No. 83 of 2026, reinforcing IEMS obligations by requiring timely and accurate responses to UAE FIU enquiries, enhanced documentation standards, strengthened internal controls and escalation procedures, and immediate compliance with instructions (including freeze orders).

Why it matters

The notice strengthens supervisory expectations around FIU engagement and AML/CFT/CPF compliance, with enforcement risk for delayed, incomplete, or inaccurate responses to regulatory enquiries.

What firms should do

• Review and update procedures for handling IEMS/goAML requests.
• Ensure clear internal escalation and response workflows.
• Train relevant staff on FIU engagement and documentation requirements.
• Implement controls to ensure timely submission and compliance with instructions.

What happened

ADGM published its 2026 LPA Risk Assessment update, confirming a broadly stable risk profile while introducing a refined five-point risk scale, identifying higher-risk structures (e.g. private companies and foundations), and highlighting vulnerabilities around complex ownership, nominee arrangements, and UBO opacity requiring enhanced scrutiny.

Why it matters

The update reinforces expectations for firms to strengthen UBO transparency, risk assessments, and monitoring of complex structures, aligning with UAE AML/CFT and FATF priorities.

What firms should do

• Update entity risk assessments to reflect LPA findings.
• Enhance due diligence for complex and higher-risk legal structures.
• Strengthen UBO verification and transparency controls.
• Monitor exposure to nominee arrangements and cross-border structures.

What happened

FSRA finalised enhancements to its AML framework by updating both the Financial Services and Markets Regulations and FSRA Rulebooks (AML, GEN and GLO), introducing strengthened governance and MLRO accountability, enhanced risk-based CDD and sanctions controls (including virtual asset requirements), and revised DNFBP registration and supervisory powers aligned with UAE Federal AML laws and FATF standards.

Why it matters

The amendments strengthen ADGM's alignment with international AML and transparency standards, particularly in relation to beneficial ownership, trust and foundation structures, and corporate governance. Restrictions on non-profit activities and the express prohibition of bearer shares reduce misuse risks, while clearer filing obligations improve regulatory certainty and compliance expectations for entities operating in ADGM.

What firms should do

• Conduct a comprehensive gap analysis across AML, GEN, and FSMR requirements.
• Review and enhance AML governance, policies, and MLRO oversight structures.
• Update CDD, DNFBP, and third-party reliance frameworks.
• Ensure alignment with UAE Federal AML legislation and FATF standards.