Aiying provides a one-stop solution for global Web3 organizations, offering ADGM license application, compliance system setup, and commercialization. Our local team has extensive ADGM oversight experience and has successfully assisted over 100 crypto and traditional financial companies in obtaining compliance licenses.
Since 2016, we have accumulated a decade of deep experience in the crypto space, combining best practices from traditional finance with the crypto industry.
We have provided actionable compliance advice and business solutions to more than 100 crypto and traditional financial companies, accumulating extensive case practice experience.
The team members come from the legal, compliance, and anti-money laundering officer positions at the world's top five cryptocurrency exchanges and asset management platforms. They possess professional qualifications from Hong Kong, Australia, Europe, the UAE, and China.
Headquartered in Asia with a global service network, we ensure 24/7 professional support and localized solutions for our clients.
Among the world's major financial centers, ADGM has become the preferred destination for global Web3 companies due to its innovative regulatory framework, strategic geographical location, and openness to Web3. The following are ADGM's core advantages compared to other major financial centers.
ADGM is among the first jurisdictions globally to establish a clear regulatory framework for digital assets. In 2018, it launched the world's first OCAB framework, providing a clear legal status for virtual asset businesses. Compared to the later-developing regulations in places like Singapore and Hong Kong, ADGM has adopted a more proactive and inclusive approach.
✓ Businesses can gain clearer legal certainty and regulatory expectations.
ADGM's legal system is based on English common law, not civil law. This is particularly advantageous for companies from common law countries, as they are more familiar with contract enforcement, case law, and legal interpretation. At the same time, English legal documents and international arbitration mechanisms provide convenience for global businesses.
✓ Reduce legal risks and compliance costs, and improve the enforceability of international business contracts.
相較於新加坡（MAS）、香港（SFC）、歐盟（MiCA）等地，ADGM的最低資本要求相對較低。交易平台最低$500,000-$2,000,000，託管服務$250,000-$1,000,000。這對新創公司和中小型Web3公司更加友善。
✓ Lower the initial investment threshold and accelerate the speed at which companies enter the market.
ADGM's licensing application typically takes 8-14 months, offering a faster time to market compared to the longer processing time of the EU's MiCA and the stringent review process of Singapore's MAS. Furthermore, FSRA's interaction with applicants is more transparent and constructive.
✓ Businesses can obtain compliance licenses more quickly and seize market opportunities.
Abu Dhabi, located in the Middle East, is a strategic hub connecting Asia, Europe, and Africa. Its time zone advantage (GMT+4) makes it an ideal center for 24-hour global trading. Furthermore, bilateral agreements between the UAE and numerous countries worldwide facilitate cross-border business operations for companies.
✓ Facilitates businesses' expansion into emerging markets such as the Middle East, South Asia, and Africa.
The UAE is one of the most stable countries in the Middle East, with a strong economic foundation and ample foreign exchange reserves. The government's clear support policies for financial innovation and Web3 provide businesses with long-term stability and predictability.
✓ Reduce geopolitical risks and provide a stable foundation for the long-term development of enterprises.
ADGM licenses are widely recognized internationally. The FSRA is an IOSCO member, and its regulatory standards are aligned with international best practices. ADGM license holders can more easily obtain recognition or establish branches in other jurisdictions.
✓ Facilitates cross-border expansion and international cooperation for enterprises
ADGM allows businesses to operate in various forms, including exchanges, custody, brokerage, and asset management. Meanwhile, FSRA adopts a more flexible regulatory approach to innovative business models (such as DeFi and NFTs), allowing businesses to innovate within a compliant framework.
✓ Businesses can flexibly choose their business model and operating method according to their own needs.
The Abu Dhabi Global Market (ADGM), established by federal law and Abu Dhabi law (No. 4/2013), is an independent international financial center. Its legal system, based on English common law, provides an ideal legal environment for fintech and Web3 businesses. ADGM boasts an independent judicial system, English-language contract enforcement, and international arbitration mechanisms.
The Financial Services Regulatory Authority (FSRA) is the single, independent body within the ADGM responsible for authorizing and regulating all financial services activities. Adhering to risk-based, proportionality-based, and innovation-supporting regulatory principles, the FSRA aims to provide a clear compliance path for legitimate and sound businesses.
ADGM is one of the world's first jurisdictions to establish a clear regulatory framework for digital assets. Its core regulatory philosophy is to classify digital assets according to their economic substance and adapt them to relevant traditional financial regulatory rules. In 2018, it launched the world's first "Operating in Cryptocurrency Assets" (OCAB) regulatory framework, providing a clear legal status for virtual asset businesses.
To conduct financial business in ADGM, you must obtain a financial services license issued by the FSRA. The first step is to determine which category(s) of "regulated activities" your planned business falls under. Below are the six main categories and their core characteristics.
ADGM operates a multi-asset trading platform (MTF) or exchange, providing clients with trading services for virtual assets or digital securities. These services include various trading methods such as spot trading, margin trading, futures trading, and options trading.
Provide transaction matching services
Repair order book
Enforce market supervision
Processing transaction settlement
Managing counterparty risk
$500,000 - $2,000,000
The capital required for operating derivatives trading is typically high, depending on factors such as trading volume, number of trading pairs, and complexity of the derivatives.
Minimum team size:15-30 people
Candidates with over 5 years of experience operating financial trading platforms must pass an FSRA suitability assessment.
More than 5 years of risk management experience, familiar with trading platform risk models
10+ years of experience in financial technology development, familiar with high-frequency trading systems
Five or more years of financial compliance experience required, FSRA approval necessary.
More than 3 years of market supervision experience, familiar with abnormal transaction detection
5-10 engineers responsible for system operation and security.
Implement an effective market surveillance system to detect and report suspicious transactions.
Establish a customer fund segregation mechanism to ensure the safety of customer assets.
Provides real-time transaction data reports and maintains transaction records.
Ensure 99.99% system availability and develop a business continuity plan.
Implement multi-layered security measures and conduct regular security audits.
Application period
8-12 months
Estimated cost
$200,000-$500,000 (including application fees, consulting fees, and audit fees)
Difficulty level
Medium to High
▸The technical system is highly complex and requires system demonstration and stress testing by FSRA.
▸Strict market supervision requirements necessitate the establishment of a robust mechanism for detecting abnormal transactions.
▸Customer funds require strict segregation and necessitate cooperation with licensed banks.
Acting as a custodian, we safeguard clients' virtual assets or digital securities. This includes cold wallet storage, multi-signature key management, regular audits, and insurance coverage.
Secure storage of customer assets
Managing private keys and mnemonic phrases
Execute customer instructions
Provide asset reports
Responding to security incidents
$250,000 - $1,000,000
The amount depends on the size and complexity of the assets under management. Initially, it typically requires $250,000-$500,000.
Minimum team size:10-20 people
Candidates with over 5 years of asset custody experience must pass an FSRA suitability assessment.
10+ years of cybersecurity experience, familiar with cryptography and cold storage technology
5+ years of managed operation experience
5+ years of financial compliance experience
3-5 people responsible for wallet management and key protection
Client assets must be completely separated from company assets, and an independent account system must be established.
Implement multi-signature key management with at least three independent signatories.
An independent audit must be conducted at least once a year to verify the integrity of the assets.
Purchase insurance for the assets under custody, with coverage no less than the total amount of assets under custody.
Develop detailed disaster recovery plans and conduct regular drills.
Application period
6-9 months
Estimated cost
$ 150,000- $ 300,000
Difficulty level
Medium to High
▸The security requirements are extremely high, and it is necessary to pass the FSRA security audit.
▸Insurance costs are high, and terms need to be negotiated with the insurance company.
▸The technology is highly complex and requires the establishment of a robust key management system.
As a broker, you represent your clients in executing or arranging transactions. This includes finding counterparties, negotiating transaction terms, and executing transaction instructions.
Finding a counterparty
Negotiated Transaction Terms
Execute customer transaction instructions
Provide market information
Managing counterparty risk
$200,000 - $500,000
It depends on the trading volume and the type of trading.
Minimum team size:8-15 people
5+ years of brokerage experience
5+ years of trading experience, familiar with the market
More than 3 years of brokerage compliance experience
3-5 people with trading experience
Disclose all potential conflicts of interest and establish an independent transaction decision-making process.
Strive for the best deal price and terms for our clients
Establish a customer fund segregation mechanism to prevent misappropriation of customer funds.
Maintain detailed transaction records and retain them for at least 7 years.
Application period
5-8 months
Estimated cost
$ 100,000- $ 200,000
Difficulty level
Medium to High
▸It is necessary to establish cooperative relationships with multiple counterparties.
▸Strict requirements for conflict of interest management
▸Requires passing the FSRA Best Performance Test
As an asset manager, you represent clients in managing their investment portfolios. This includes investment decisions, portfolio management, risk management, and performance reporting.
Develop investment strategies
Executing investment decisions
Managing Portfolio
Monitoring risks
Provide performance reports
$300,000 - $1,000,000
It depends on the assets under management (AUM).
Minimum team size:12-25 people
Requires 10+ years of investment management experience and must pass the FSRA suitability assessment.
5+ years of investment management experience, 3-5 people
5+ years of risk management experience
More than 5 years of asset management compliance experience
3-5 people responsible for market research and investment analysis
Develop a detailed Investment Policy Statement (IPS) to clearly define investment objectives and strategies.
Establish a comprehensive risk management framework, including VaR and stress testing.
Provide clients with regular performance reports, disclosing costs and risks.
Reveal all potential conflicts of interest and establish an independent investment decision-making process.
Understanding the client's risk tolerance and investment goals
Application period
6-10 months
Estimated cost
$ 150,000- $ 350,000
Difficulty level
Medium to High
▸A sound risk management framework needs to be established.
▸Investment capacity assessment by FSRA is required.
▸Sufficient initial AUM is needed to support operations.
Provide customers with loans, financing, or other credit facilities, including margin financing, mortgage loans, and lines of credit.
Assess borrower credit
Drafting loan terms
Loan issuance
Monitoring loan risks
Handling non-performing loans
$500,000 - $2,000,000
It depends on the scale of financing and the level of risk.
Minimum team size:15-30 people
10+ years of experience in financing or banking
10+ years of credit risk management experience
5+ years of credit assessment experience, 3-5 people
More than 5 years of experience in financing compliance
3-5 people responsible for loan monitoring and risk management
Establish a comprehensive credit assessment system to evaluate borrowers' repayment ability.
Keep complete loan documents, including loan agreements, collateral documents, etc.
Establish a loan portfolio risk management framework to monitor concentration risk.
Formulate policies for handling non-performing loans and dispose of bad debts in a timely manner.
Conduct thorough due diligence on borrowers and monitor suspicious transactions.
Application period
8-12 months
Estimated cost
$ 200,000- $ 500,000
Difficulty level
Medium to High
▸A sound credit assessment system needs to be established.
▸Risk management assessment by FSRA is required.
▸Sufficient financing is needed to support the business.
Provides payment, remittance, or other transfer services, including stablecoin payments, fiat currency exchange, and international remittances.
Processing payment transactions
Execute remittance instructions
Managing liquidity
Monitoring transactions
Handling disputes
$250,000 - $750,000
It depends on the trading volume and the level of risk.
Minimum team size:10-20 people
5+ years of experience in payment or remittance business
5+ years of payment operations experience
5+ years of payment compliance experience, especially AML/CFT
3-5 people responsible for transaction monitoring and reporting suspicious activities.
3-5 people to handle customer disputes
Implement strict anti-money laundering and counter-terrorism financing measures, including CDD, KYC, and transaction monitoring.
Conduct thorough identity verification and due diligence on all clients.
Establish a real-time transaction monitoring system to detect suspicious transactions.
Report suspicious activities to FSRA promptly.
Client funds must be held in a trust account to be segregated from company assets.
Application period
6-9 months
Estimated cost
$ 150,000- $ 250,000
Difficulty level
Medium to High
▸AML/CFT requirements are extremely stringent, necessitating the establishment of a comprehensive monitoring system.
▸It is necessary to establish cooperative relationships with multiple banks.
▸AML/CFT assessment by FSRA is required.
The FSRA licensing application is a highly interactive and rigorous process that typically takes 8-14 months. The entire process is divided into five key stages.
Before formal submission, conduct initial communication with the FSRA authorization department.
Prepare a complete application package, including the main form, supplementary forms, supporting documents, etc., and submit it to FSRA.
The FSRA conducts an initial review of the application and may raise questions or request supplementary documents. This is a highly interactive process.
FSRA conducts in-depth assessments, including on-site inspections, technical demonstrations, and stress tests.
The FSRA will make the final decision, and if approved, will issue a financial services license.
Successfully obtaining an ADGM license requires a complete application package. Below is the core requirements and document checklist.
Form 1: Application for Authorisation
Form 2: Applicant Information Form
Form 3: Senior Management and Directors Information
Regulatory Business Plan - Detailed explanation of business model, market, and risk management
Organizational Structure and Governance Documents – Articles of Association, Board Resolutions, Shareholding Structure
Financial documents – Balance sheet, cash flow forecasts, capital adequacy ratio calculations
Compliance and Risk Management Framework – AML/CFT Policy, Risk Management Framework, Internal Audit Plan
Technical and security documentation – system architecture, security measures, disaster recovery plan (if applicable)
Background of senior executives and employees – resumes, suitability assessments, and criminal record checks
Trading platform: trading rules, market supervision policies, risk management models
Managed services: cold storage policy, multi-signature management procedures, insurance certificate
Asset Management: Investment Policy Statement, Fund Documents, Performance Report Templates
Payment services: transaction monitoring system, customer identification program, suspicious activity reporting process
After obtaining an ADGM license, companies need to meet a series of ongoing compliance requirements.
Minimum capital requirements
Depending on the type of business, the minimum capital requirement ranges from $200,000 to $2,000,000. The capital must consist of real funds and cannot be loans.
Capital adequacy ratio
A minimum capital adequacy ratio needs to be maintained (typically 8%-15%, depending on the type of business). Regular reporting to the FSRA is required.
Financial reporting
Audited financial statements must be submitted annually. For high-risk businesses, more frequent reporting may be required.
Customer due diligence (KYC)
Conduct thorough identity verification and background checks on all clients. Understand the nature of their business, the source of their funds, etc.
Transaction monitoring
Establish a real-time transaction monitoring system to detect suspicious transaction patterns. A clear escalation and reporting process is required.
Suspicious Activity Report (SAR)
Report suspicious activity to the FSRA promptly. This is typically required within 10 business days of discovery.
staff training
Regularly conduct AML/CFT training for employees to ensure that everyone understands the compliance requirements.
Suitability of senior executives
All senior executives and key personnel must pass the FSRA suitability assessment. They need to demonstrate the necessary knowledge, experience, and integrity.
Internal Control
Establish a sound internal control framework, including risk management, internal audit, and compliance monitoring.
Board of Directors Oversight
The board of directors must effectively oversee the company's compliance efforts. Compliance reports need to be reviewed regularly.
Customer Fund Segregation
Client funds must be completely segregated from company assets and held in a separate trust account.
Risk Management Framework
Establish a comprehensive risk management framework, including market risk, credit risk, liquidity risk, and operational risk.
information security
Implement multi-layered security measures to protect customer data and transaction information. Conduct regular security audits and penetration tests.
Based on our experience assisting 100+ companies, here are key tips for obtaining an ADGM license.
Conduct thorough pre-application communication. This can help you understand FSRA's expectations and avoid application rejection or delays.
It can clearly explain your business model, target market, and competitive advantages.
Ensure all documents are complete, accurate, and professional. Missing or unclear documents can cause application delays.
Demonstrate your deep understanding of business risks and how to effectively manage them.
Establishing a robust compliance framework from the outset is not only a requirement of the FSRA, but also the foundation for long-term operations.
Ensure you have sufficient capital to not only meet the minimum requirements but also support business growth.
If trading or custody is involved, ensure that the technical systems comply with FSRA requirements. This typically requires system demonstrations and stress testing.
Establishing a local presence at ADGM, including offices, staff, and local consultants, demonstrates your commitment to the market.
Ensure that senior executives and key personnel possess the necessary experience and qualifications. This is crucial for passing the FSRA suitability assessment.
Maintain good communication with FSRA throughout the application process. Respond promptly to information requests and proactively provide supplementary information.
Our local team consists of seasoned financial regulatory experts with extensive experience in ADGM license application and compliance practices.
partner
A highly qualified corporate and innovation lawyer with nearly a decade of experience. Possesses deep expertise in developing government economic strategies, driving regulatory reform, and supporting innovation.
✓ Master of Laws degree from Rotterdam University of Applied Sciences
✓ Bachelor of Business Administration (Real Estate Development) from Rotterdam University of Applied Sciences
✓ Yale University Graduate Degree in Financial Markets, Finance, and Financial Management Services
✓ Master of Corporate Governance
partner
Experienced investment managers and advisors, renowned for their expertise in fintech and investment strategies. Specializes in helping entrepreneurs establish businesses and access advanced business environments in the UAE and GCC region.
✓ Master of IT
✓ In-depth understanding of global financial markets
✓ Financial and technological integration expertise
It typically takes 8-14 months, depending on the complexity of the business and the completeness of the documentation. Early communication with FSRA can expedite the process.
根據業務類型，最低資本要求從$200,000到$2,000,000不等。交易平台通常需要$500,000-$2,000,000，託管服務需要$250,000-$1,000,000。
Continuous compliance requirements must be met, including capital adequacy ratios, AML/CFT, financial reporting, staff training, and risk management. The annual oversight fee is $5,000-$30,000.
Both ADGM and DFSA are international financial centers in the UAE, but they have different regulatory frameworks. ADGM is based on English common law, while DFSA is based on international best practices. Which one you choose depends on your business model and target market.
FSRA typically provides detailed reasons for rejection. You can improve your application based on the feedback and then reapply. We can help you analyze the problem and prepare an improvement plan.
An ADGM license is valid within ADGM. If you wish to operate in other countries, you will need to obtain a local license or permit. We can assist you in developing a cross-border compliance strategy.
We can assist you with comprehensive compliance assessments, preparing application documents, communicating with the FSRA, and establishing a compliance framework. Our team has extensive experience with ADGM applications, which can significantly increase your success rate.
It's not required, but establishing a local presence is recommended before approval. This demonstrates your commitment to the market and helps gain the FSRA's trust.