
ME-ALLIANCE LEGAL UPDATE
The Abu Dhabi Global Market (“ADGM”) Registration Authority (“RA”) has published amendments to ADGM’s commercial legislation aimed at strengthening transparency, enhancing regulatory oversight, and supporting compliance with international anti-money laundering (“AML”) and counter-terrorist financing (“CTF”) standards. The amendments introduce targeted changes to ADGM’s beneficial ownership and transparency framework, with particular focus on nominee arrangements, trusts, certain cash transactions, and branches of foreign legal persons registered in ADGM.
Key Amendments
Public Disclosure of Nominee Status: The ADGM public register will indicate whether a shareholder or director is acting in a nominee capacity, providing greater transparency over corporate ownership and control arrangements.
Beneficial Ownership Information for Trusts: The Registrar has been granted express powers to request beneficial ownership information relating to trusts connected with ADGM, strengthening regulatory access to information concerning the ownership and control of legal arrangements.
Restrictions on Cash Transactions: New licensing conditions prohibit certain designated non-financial businesses and professions, including legal, accounting, company service and real estate businesses, from accepting or distributing cash payments above prescribed thresholds.
Requirements for Registered Branches: Branches of foreign legal persons registered in ADGM will be required to maintain and provide beneficial ownership information relating to their foreign parent entities.
Key Takeaway
The amendments reinforce ADGM’s focus on transparency and effective AML/CTF regulation. Businesses operating within ADGM should assess whether the new requirements apply to their activities and review their beneficial ownership records, nominee arrangements and relevant payment procedures accordingly.
The amendments became effective upon publication on 9 July 2026.
