Crypto
Mar 27, 2025
As the Web3 sector rapidly evolves, firms eager to dive into the Dubai crypto scene can’t afford to get bogged down by red tape. Instead, they need to get their operations up and running quickly to stay competitive. Getting an ADGM crypto license is one way to smooth the transition into the local market, but the process can be complex and daunting.
This guide will demystify what it takes to secure an ADGM crypto license and provide valuable insights to help you get expert legal solutions on Web3 Dubai. Ape Law's Web3 legal experts can help ease the burden of securing an ADGM crypto license. Our trusted legal team brings years of experience navigating the intricacies of crypto regulations in Dubai and can help you achieve your goals quickly and efficiently.
Table of Contents
Who Needs an ADGM Crypto License?
Before engaging in crypto-related activities in ADGM, businesses must obtain the appropriate license based on the services they plan to offer. The ADGM’s licensing structure ensures that companies follow specific regulatory guidelines tailored to their operations, ensuring transparency and security. Below are the various licenses available for those operating in the virtual assets space within ADGM.
Managing Virtual Assets
This license is for businesses that manage virtual assets on behalf of clients with discretion. It involves overseeing and making decisions regarding digital currencies and assets as part of a managed portfolio.
Operating as a Virtual Assets Custodian
This license is required for firms that store virtual assets for clients. Actions are taken based on clear, verified instructions from the asset owner or their representative, ensuring secure storage like a digital safe deposit box.
Exchange Services with Multilateral Trading Facility (MTF)
This license is necessary for operating a platform where multiple buyers and sellers trade virtual assets. It functions similarly to a traditional stock exchange but specifically for cryptocurrencies.
Arranging Virtual Assets
This license pertains to businesses that facilitate deals for the buying or selling virtual assets. It includes acting as either the main party in a transaction or as an agent promoting it.
Dealing in Virtual Assets
This license is for businesses that directly buy or sell virtual assets, manage transactions such as subscriptions, or underwrite crypto financial instruments.
Advising on Virtual Assets
This license is for firms that provide advisory services on the buying or selling specific virtual assets. It involves offering guidance on crypto investments, whether for the firm’s benefit or on behalf of clients.
Importance of ADGM Crypto License
Legal Framework Supports Cross-Border Activities
The legal environment in ADGM is designed to support cross-border operations. This is particularly important for crypto businesses, which often operate internationally. Furthermore, no restrictions exist on foreign employees so you can hire the best talent worldwide.
Tax Efficiency Boosts Your Bottom Line
ADGM offers a 50-year guarantee of zero tax on profits, capital, or assets and no tax on personal income. This allows you to maximize your revenues and attract top global talent who won’t be penalized for their earnings.
Sound Regulatory Oversight Builds Confidence
ADGM is home to the Financial Services Regulatory Authority, an independent regulator with a solid reputation. The judicial system is independent, English-speaking, and based on common law, distinct from the UAE’s civil courts. Furthermore, the regulatory approach is risk-based, meaning compliant businesses aren’t penalized unnecessarily.
A Thriving Ecosystem for Crypto Firms
ADGM is a prominent hub for deal-making in the region, boasting a concentration of international financial institutions. The ecosystem also includes world-class regional and global professional services and is home to a growing fund domicile.
A Geographic Epicenter for Your Operations
ADGM is strategically located to support operations in the Middle East, Africa, and South Asia. This region is increasingly the center of gravity for the global economy. The UAE plays a central role in the growing South-South trade, particularly between Asia and Africa, and ADGM is well-positioned to equip the potential of emerging markets. Setting up a crypto business in the UAE can be complex, but Ape Law makes it smooth. 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 easily navigate the legalities of creating a Web3 business in the UAE!
Related Reading
• Is Crypto Trading Legal in UAE
• UAE Crypto
• VARA License Cost
How to Get the ADGM Crypto License in UAE in 5 Simple Steps
1. Use Ape Law for Legal Solutions
Setting up a crypto business in the UAE can be complex, but Ape Law makes it smooth. 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 easily navigate the legalities of creating a Web3 business in the UAE!
2. Initial Application Process
Start by familiarizing yourself with the ADGM and FSRA. Prepare and submit a business plan (regulatory business plan) with financial projections to the FSRA. Finalize the RBP based on the FSRA’s comments. Prepare a complete application, including KYC policies, processes, and documentation for key personnel. Submit a formal application to the FSRA for initial review. Conduct a detailed review, including ongoing communication with the FSRA and interviews with key personnel.
3. Final Steps for Approval
Address any conditions set by the FSRA. Establish a legal entity, open a bank account for share capital, select auditors, and secure professional indemnity insurance. Complete the final FSRA submission to receive Financial Service Permissions.
4. Costs
Listing and trading admission fees: US$ 3,000. A sliding-scale monthly trading levy is payable to the FSRA by virtual asset exchanges operating as MTFs.
5. Data Protection
Registration for data protection notification is a step in registering a new entity in ADGM, costing US$ 300 initially and for annual renewals.
Related Reading
• VARA UAE
• VASPs
• DMCC Crypto License
Regulation of ADGM Crypto License in UAE
Abu Dhabi Global Market has cultivated a detailed regulatory framework for crypto assets, making it a top destination for virtual asset activities in the United Arab Emirates. This framework aims to balance innovation in the financial sector with robust investor protection and financial system integrity.
Initial Guidance on Crypto Regulation
The Financial Services Regulatory Authority introduced its initial "Guidance for the Regulation of Crypto Asset Activities" in June 2018 and released an enhanced version in May 2019. This updated guidance addresses several key areas.
Crypto Stablecoins
Stablecoins fully backed by fiat currencies, termed "Fiat Tokens," are treated as digital representations of money. When used as payment instruments, they fall under the activity of Providing Money Services and are regulated accordingly.
Crypto Custody
The guidance clarifies permissible crypto asset custody activities, emphasizing governance and operational expectations for custodians.
Technology Governance
It outlines expectations for managing technological changes, such as protocol forks, ensuring that exchanges and license holders maintain robust governance and control mechanisms.
AML and Sanctions Compliance
The AML Rulebook applies fully to crypto asset operators. The guidance incorporates recent local and global changes and clarifies the use of regulatory and surveillance technologies.
Licensing Crypto Businesses
Entities seeking to operate crypto asset businesses within ADGM must obtain a Financial Services Permission from the FSRA. The application process thoroughly assesses the applicant's business model, internal controls, compliance with AML and Counter-Terrorist Financing requirements, and adherence to the FSRA's Conduct of Business Rulebook. Applicants must demonstrate robust governance structures, risk management policies, and technological infrastructure to ensure the integrity and security of their operations.
Ongoing Compliance Obligations
Licensed crypto asset businesses are subject to ongoing compliance obligations, including:
AML and CTF Measures
Implementing comprehensive policies and procedures to detect and prevent money laundering and terrorist financing activities.
Consumer Protection
Ensuring transparent communication with clients, fair treatment, and safeguarding of client assets.
Technology Risk Management
Maintaining robust IT systems with measures to address cybersecurity threats and operational risks.
Regulatory Reporting
Regularly submitting financial reports and disclosures to the FSRA facilitates ongoing regulatory oversight.
Recent Developments
ADGM continues to enhance its regulatory framework in response to the evolving crypto asset landscape. The FSRA is preparing further guidance on digital securities for primary and secondary market considerations, reflecting its commitment to fostering a well-regulated and innovative financial ecosystem.
