ADGM AML requirements

The Rulebook defines a Designated Non-Financial Business or Profession as the class of persons carrying on any of the following businesses in ADGM[FSRA — AML and Sanctions Rulebook]:

1. A real estate agency carrying out transactions for or on behalf of a customer involving the buying or selling of real property.
2. A dealer in precious metals or precious stones.
3. A dealer in any saleable item of a price equal to or greater than USD 15,000.
4. An accounting firm, audit firm, insolvency firm or taxation consulting firm.
5. A Legal Professional.
6. A Company Service Provider.

Read item three carefully, because it is the widest and the most missed. Any dealer in any saleable item priced at USD 15,000 or more is a DNFBP. Not a jeweller specifically — any dealer. Art, watches, classic cars, machinery, yachts, high-value furniture. If your business sells single items above that threshold, you are inside the Rulebook regardless of sector.

Why CSPs are on the list

Company service providers form entities and provide registered addresses, which is precisely the function money laundering typologies target. It is also why CSP work is a controlled activity requiring an ADGM licence[ADGM RA — Al Reem guidance note], and why choosing a CSP is partly a compliance decision rather than only a price one. Your provider's AML obligations are the reason their onboarding asks you so much.

The Rulebook does not apply uniformly. Rule 1.2.1 scales it by the type of Relevant Person[FSRA — AML and Sanctions Rulebook]:

• Authorised Persons other than a Credit Rating Agency, and Recognised Bodies — Chapters 1 to 14.
• Representative Offices — Chapters 1 to 6 and 11 to 14.
• DNFBPs — Chapters 1 to 9 and 11 to 15.
• NPOs — Chapter 16 only.

The Representative Office carve-out has a stated logic: Chapters 7 to 9 deal with customers, and a Representative Office does not have customers, so they do not apply[FSRA — AML and Sanctions Rulebook].

The FSRA is explicit that this table is guidance only and that relevant persons should consider the chapters and determine which provisions apply to them[FSRA — AML and Sanctions Rulebook]. Treat the mapping as orientation, not as a compliance opinion.

What sits in the chapters everyone shares

Chapters 1 to 6 reach every category. They cover the general compliance requirements — group policies where you sit in a group, notifications, record keeping, the annual AML return, co-operation with the Regulator, employee disclosures and high-risk jurisdictions — then the risk-based approach and the business risk assessment[FSRA — AML and Sanctions Rulebook].

The annual return is worth diarising. It is a recurring filing obligation independent of whether anything has happened.

A Relevant Person must appoint an individual as the MLRO — the Money Laundering Reporting Officer — who has appropriate seniority and experience[FSRA — AML and Sanctions Rulebook].

Three things follow that are easy to get wrong in a small entity.

It is an individual, not a function. A named person holds it. You cannot satisfy the requirement by pointing at a team or a service.

Seniority is part of the test. Appointing a junior administrator because they have capacity does not meet a requirement framed around appropriate seniority and experience.

Responsibility is allocated, not diffuse. The Rulebook applies both to the Relevant Person and to the persons specified as responsible for that person's compliance[FSRA — AML and Sanctions Rulebook]. Compliance failures land on identified people.

ADGM publishes a checklist of the documents required for appointing an MLRO, and the Registration Authority's guidance points applicants at it[ADGM RA — Al Reem guidance note]. If you are incorporating and will need one, that appointment belongs in the setup plan rather than after launch.

Establish your category before you build anything. Whether you are an Authorised Person, a DNFBP or neither determines which chapters bind you, and the answer follows from your activity rather than your preference. See licence categories and the FSRA.

Do not assume non-financial means out of scope. Six categories of ordinary commercial business are DNFBPs, including a dealer in any item at USD 15,000 or more[FSRA — AML and Sanctions Rulebook].

Budget for the function, not just the filing. An MLRO of appropriate seniority, a business risk assessment, record keeping and an annual return are ongoing operating costs. They belong in the same column as the licence renewal and the CSP fee, not in a one-off setup line. See what ADGM actually costs to run.

What this page is not

This is an orientation to who the Rulebook catches and how it scales. It is not an AML compliance programme, and we are not licensed to design one. The Rulebook runs to sixteen chapters and the FSRA expects each relevant person to work out which provisions apply to it[FSRA — AML and Sanctions Rulebook]. For a live obligation, read the Rulebook itself and take advice from someone regulated to give it.