Crypto
Jun 28, 2025
If you run a business in the UAE crypto space or want to start one, the ADGM activity list is a valuable resource you should understand. This list outlines the various activities permitted within the free zone. Not only does it guide businesses in the crypto space in establishing their operations, but it also helps them stay compliant with local regulations as they grow. In this article UAE crypto, we will examine the ADGM activity list and discuss how it can benefit your cryptocurrency business.
To keep your business on the right track, Ape Law's Web3 Legal Experts can help you interpret and comply with local regulations, including the ADGM activity list. Our team of experienced crypto lawyers can help you understand any legal documents and provide you with tailored strategies to achieve your objectives.
Table of Content
Advantages of Setting Up in ADGM
Businesses seeking an ADGM license must demonstrate an economic presence within the jurisdiction, which involves maintaining a physical office and employing staff to operate from it. This requirement aims to ensure that companies are not merely using ADGM as a regulatory arbitrage opportunity but are instead genuinely committed to operating in the Abu Dhabi financial ecosystem.
With this in mind, here are the types of companies that should consider applying for an ADGM license: Crypto firms, including exchanges, brokers, and other intermediaries; Asset managers, especially those focused on digital assets and crypto; Funds and entities looking to establish a presence to manage or invest in digital assets; Family offices and proprietary trading firms; Technology firms developing solutions for the crypto space.
The Legal Framework Supports Cross-Border Activities
The legal framework in the ADGM enables cross-border activities and provides for the enforcement of international contracts. It allows for 100% foreign ownership with no restrictions on capital repatriation or the employment of foreign nationals. For instance, Anglo-Gulf Trade Bank (AGTB) is a digital trade finance bank launched as a joint venture between Mubadala and Anglo-Gulf Trade Bank Limited, which chose the ADGM for its legal clarity and global integration. It leveraged the English common law system, which is essential for cross-border trade financing and the enforceability of international contracts, resulting in a quick launch, a compliant structure, and strong investor confidence.
Tax Efficiencies
Another significant advantage of setting up in the ADGM is the tax efficiencies, as there is zero tax for 50 years on profits, capital, or assets, as well as zero tax on personal income. Multinational fund managers setting up in the ADGM are particularly attracted to this regime. International hedge funds and asset managers—such as Dalma Capital—have chosen the ADGM due to its zero-tax regime for 50 years on profits and capital gains. This enables them to offer tax-neutral structures to investors, helping them compete globally with financial hubs such as Luxembourg or the Cayman Islands.
Confidence
The ADGM has a well-regarded, independent regulator, the Financial Services Regulatory Authority (FSRA), which is distinct from the UAE's civil courts and features an English-speaking, standard law judicial system. The ADGM adopts a risk-based regulatory approach that is both flexible and robust, enabling innovation in FinTech and professional services. Global firms, such as KPMG, PwC, and other Big Four companies, have chosen the ADGM due to its risk-based regulatory framework, which supports their operations and fosters confidence. The FSRA is well-respected for its independence and transparency.
Ecosystem
The ADGM has a high prominence in deal-making in the region and is home to a concentration of international financial institutions as well as world-class regional and global professional services. The jurisdiction has also emerged as a growing fund domicile in the region. For example, Hub71 is Abu Dhabi’s tech ecosystem, hosted in the ADGM, which supports over 200 startups. These startups benefit from access to investors, legal support, tax benefits, and proximity to regional deal-making. Global players, including Microsoft, SoftBank, and Mubadala, are active partners.
Geographic Epicentre
Setting up in the ADGM allows management offices, holding companies, and family offices to be located closer to the assets they own or manage. The Middle East, Africa, and South Asia (MEASA) is increasingly the center of gravity for the global economy, and the UAE plays a central role in the growing South-South trade, principally between Asia and Africa.
This makes the ADGM well-positioned to harness the potential of emerging markets. Many Indian and African high-net-worth individuals and conglomerates are establishing holding companies in the ADGM to be geographically closer to the MEASA markets, benefiting from time zone overlap, trade connectivity (via the Asia-Africa corridor), and regulatory trust, as well as global reach.
Related Reading
• DIFC Innovation Hub
• ADGM Abu Dhabi
• DIFC FinTech Hive
• Crypto Exchange UAE
Types of Entities in ADGM
Public Company Limited by Shares: The Open Shareholder
A Public Limited Company (PLC) can issue shares to the public, making it an ideal structure for firms looking to raise capital from a wide range of investors. An ADGM PLC requires a minimum share capital of USD 50,000 and at least two shareholders (one of whom must be an individual) and a company secretary. Shareholder liability is limited to their shareholding.
Private Company Limited by Shares: The Family Firm
A Private Company Limited by Shares (LTD) cannot offer shares to the public and is typically owned by a small group of family members or friends. An ADGM LTD requires at least one individual shareholder and one director (who may be an individual or a corporate entity). There is no minimum capital requirement, and a secretary is optional. The liability of the shareholder is limited to the amount paid or unpaid on the shares held by the shareholder.
Private Company Limited by Guarantee: The Nonprofit
A Private Company Limited by Guarantee is an ideal structure for nonprofit organizations and member associations. This structure does not distribute profits or divide assets into shares. An ADGM Private Company Limited by Guarantee requires one guarantor and one director, with no minimum share capital or secretary requirement.
Restricted Scope Company: The Confidential Entity
A Restricted Scope Company is designed for entities prioritizing confidentiality and lighter compliance (e.g., family offices). This entity allows limited public disclosure. An ADGM Restricted Scope Company can only be formed under specific conditions, such as being a subsidiary of a publicly listed group or a subsidiary of a company formed by an Emiri decree or by an individual or members of the same family.
Private Company Unlimited with or without Shares: The Risky Venture
A Private Company Unlimited with or without Shares can be an attractive structure for businesses whose shareholders are willing to accept the risks associated with unlimited liability. Unlimited companies carry no restriction on shareholder liability. While not requiring a minimum share capital, they demand one shareholder and one director. Secretary service is optional.
Branch of a Foreign Company: The Foreign Entity
A branch of a foreign company is a helpful structure for foreign companies seeking to establish a small presence in ADGM. This setup requires one authorized signatory.
Setting up a crypto business in the UAE can be complex, but Ape Law makes it seamless. As Web3-native legal experts, we handle crypto licensing, business structuring, and compliance so you can focus on growth. Whether you're launching a new coin, token, and/or NFT, expanding operations, or optimizing for tax efficiency, our team ensures a smooth and legally sound setup. Ready to establish your business in the UAE? Book a free consultation today to navigate the legalities of setting up a Web3 business in the UAE with ease!
Detailed Guide on ADGM Activity List
Financial Activities (Category A)
DGM's activity list is anchored by financial services activities, which create a compelling proposition for firms in banking, investment, and asset management.
Key activities include
Investment banking – Corporate finance advisory, M&A, debt issuance, and underwriting.
Fund management – Asset and wealth management firms managing private equity, venture capital, hedge, and real estate funds.
Brokerage services – Firms licensed to trade securities or derivatives on behalf of clients.
FinTech and digital finance – Crowdfunding platforms, robo-advisors, digital wallets, and token-based investment vehicles (regulated under FSRA’s FinTech framework).
Family offices – Providing wealth structuring, estate planning, and investment management for ultra-high-net-worth families.
Who sets up here? Goldman Sachs, Mubadala Capital, Chimera Capital, and international hedge funds.
Non-Financial Activities (Category B)
ADGM offers non-financial licenses to firms providing supportive or professional services that complement the financial ecosystem.
Non-financial activities include
Oil & gas field services – Engineering and technical firms offering healthy maintenance, equipment installation, and drilling tower setup.
Consulting services – Business setup advisors, management consultants, and sustainability consultants.
Legal services – Local and international law firms offering commercial, M&A, and arbitration law under ADGM’s standard law system.
Corporate services – Registered agents, company secretarial providers, compliance firms.
Example activities from your file:
Natural gas and oil well repair
Onshore/offshore oil & gas facility services
Equipment installation for wells
Drilling tower repair
These are likely licensed to support asset-heavy operations (like sovereign investment in energy) or family holdings.
Retail Activities (Category C)
ADGM grants retail licenses sparingly and usually ties them to premium or high-value offerings that align with its brand as a luxury and high-net-worth zone.
Retail activities permitted include
Gourmet and premium food production – including bakery products, dairy processing, and meat and fish preservation for niche markets.
Lifestyle and luxury goods – Boutique shops, designer showrooms, or limited luxury retail concepts.
Hospitality services – Small cafes, premium food outlets, or concierge services supporting high-end clientele.
Examples from your file:
Manufacture of bakery or dairy products
Processing and preserving meat or seafood
Production of premium packaged foods for export
These often serve ADGM-based family offices, business travelers, or luxury-oriented investors.
Professional & Support Services
ADGM’s business infrastructure relies heavily on professional and support services, which can be licensed under non-financial categories.
Key services include
Audit and assurance services – Offered by Big Four firms like PwC, KPMG, and EY, Accounting and bookkeeping
Risk advisory and compliance – Firms helping financial entities meet FSRA or FATF compliance.
Recruitment and HR consulting – Especially for finance and legal roles.
Special Purpose Vehicles (SPVs)
While not an "activity" per se, SPVs are widely used in ADGM for structuring purposes.
Use cases
Holding intellectual property or shares
Asset isolation and securitization
Real estate or aircraft leasing structures
Family trust structures and SPVs are popular due to their no minimum capital requirements, quick setup, and tax-neutral advantages.
Technology and Innovation (via Hub71 and beyond)
ADGM has licensed many tech startups and venture studios through Hub71 and its innovation licenses.
Typical activities
Software development
AI and data analytics services
Platform-based financial solutions
Cybersecurity and digital infrastructure
Blockchain-based solutions under FSRA’s DLT guidance
Related Reading
• FSRA Abu Dhabi
• ADGM SPV
• Crypto Trading in UAE
• Crypto Exchange Abu Dhabi
Difference Between ADGM and DIFC
Legal Frameworks: Where Do You Want to Be Litigating?
Both the ADGM and DIFC have distinct legal frameworks. The ADGM adopts English common law principles and applies nearly 50 English legal statutes, meaning that English court precedents can be binding unless local laws provide otherwise. Conversely, while the DIFC is also based on English common law principles, it applies its codified regulations, meaning that English cases are only persuasive, not binding.
Court Systems: An Overview of How Each Financial Free Zone Resolves Disputes
Court systems are another significant point of difference between the ADGM and DIFC. The ADGM Courts comprise two levels (First Instance & Appeal) and are staffed exclusively by judges from common-law jurisdictions, leveraging UK case law directly. DIFC Courts (First Instance, Appeal, and Small Claims Tribunal) feature a mix of common-law and UAE civil-trained judges. Their statutes guide decisions, and English law is persuasive only.
Companies Law: Which Financial Free Zone Has the Better Regulatory Framework for Business?
Both the ADGM and DIFC have their distinct regulatory frameworks for company law, which are based on English law. The ADGM Companies Law is based on the UK Companies Act 2006, providing a more modern and refined framework for corporate governance. In comparison, the DIFC derived its Companies Law from the older UK Companies Act 1985, with lingering provisions, such as restrictions on financial assistance.
Insolvency: A Comparison of the ADGM and DIFC
Insolvency frameworks are another area of difference between the ADGM and DIFC. ADGM supports contemporary rescue mechanisms, such as administration and deed of company arrangement, mirroring UK law. On the other hand, the DIFC omits some modern restructuring techniques (e.g., administration), adhering to older insolvency constructs.
Arbitration: How the ADGM and DIFC Approach Alternative Dispute Resolution
The ADGM and DIFC also have different approaches to arbitration. The ADGM collaborates with the ICC Arbitration Centre, leveraging ICC rules and providing full procedural support. DIFC has its own Arbitration Law but generally relies on default rules (e.g., DIAC) unless parties choose otherwise.
Speed and Cost of Licensing: Which Financial Free Zone Is More Business-Friendly?
There are considerable differences in the speed and cost of licensing between the ADGM and DIFC. ADGM typically offers faster approvals and more granular fee structures—e.g., individual activity licensing, which may cost approximately $5,000 per line, with approvals often taking around eight weeks. DIFC tends to be more expensive and slower (4–6 months), with flat fees depending on the highest license category (e.g. $15k–$70k).
Focus and Ecosystem: How Each Financial Free Zone’s Structure Supports Business
The ADGM and DIFC have different areas of focus and ecosystems. DIFC is well-established (since 2004), home to 5,000+ firms, a significant wealth hub, and hosts initiatives like FinTech Hive and the nascent metaverse programme. ADGM, although relatively new (established in 2015), has rapidly gained traction, building digital courts, launching a robust fintech sandbox, and attracting crypto and digital asset innovators, such as Solana.
Digital Assets and FinTech Focus: Comparing the ADGM and DIFC
The ADGM and DIFC have different focuses when it comes to digital assets and fintech. The ADGM FSRA introduced a comprehensive Virtual Asset Framework in 2018, covering trading, custody, staking, lending, and tokenization. DIFC DFSA allows a narrower token regime (e.g., Bitcoin & Ethereum) through its sandbox. Broader Web3 and NFT innovation is expanding elsewhere (Dubai’s VARA).
Strategic and Geographical Position: Where Should You Set Up?
Finally, the ADGM and DIFC have different strategic and geographical positions. DIFC, located in central Dubai, offers deep global links and a strong track record in traditional finance. ADGM, located on Al Maryah Island in Abu Dhabi, is closer to the UAE’s sovereign funds and capital stakeholders, and favors fintech and government-linked financial ventures.
Book a Free Consultation to Navigate the Legalities of Setting up a Web3 Business in the UAE
Opening a crypto business in the UAE can be complex, but Ape Law makes it seamless. As Web3-native legal experts, we handle crypto licensing, business structuring, and compliance so you can focus on growth. Whether you’re launching a new coin, token, and/or NFT, expanding operations, or optimizing for tax efficiency, our team ensures a smooth and legally sound setup.
Ready to establish your business in the UAE? Book a free consultation today to navigate the legalities of setting up a Web3 business in the UAE with ease!
Related Reading
• ADGM License Categories
• DMCC Crypto License Cost
• DFSA Regulations
• ADGM Activity List
• Security Token
• DLT
• VARA Regulations
