The Abu Dhabi Global Market Financial Services Regulatory Authority has published a consultation paper on proposed enhancements to its anti-money laundering framework, focused on aligning the Financial Services and Markets Regulations 2015 and the Anti-Money Laundering and Sanctions Rulebook with the UAE’s new federal AML laws. The package also updates rules on correspondent banking, electronic funds transfers, and virtual asset or fiat-referenced token transfers, while reorganising and clarifying the rulebook. The FSRA says the changes should largely have minimal impact on existing compliance requirements for Relevant Persons, including Authorised Persons, Recognised Bodies, designated non-financial businesses or professions, and non-profit organisations. Key proposals include moving the prohibition on unlicensed DNFBP activity and related registration and licensing requirements into FSMR, clarifying possible delegation arrangements between the FSRA and the ADGM Registration Authority, and aligning definitions across FSMR and the AML Rulebook. Senior Management would be required to approve AML/TFS systems and controls and business risk assessments, receive regular information on their operation, and approve continuation of customer relationships under enhanced customer due diligence. The draft also clarifies customer risk assessment and customer due diligence rules, including mandatory high-risk ratings for foreign politically exposed persons, customers exposed to high-risk jurisdictions, and customers seeking transfers to or from unhosted wallets, and revises rules on third-party and outsourced CDD, business partner due diligence, correspondent banking, and MLRO approvals. For transfers, the FSRA proposes separate and more explicit requirements for electronic funds transfers and for virtual asset or fiat-referenced token transfers, with distinct obligations for originating and beneficiary institutions, counterparty due diligence and record-keeping, differentiated treatment for domestic or sub-USD 1,000 transfers versus cross-border or higher-value transfers, and specific requirements for unhosted wallets. Comments are due by 14 May 2026. The FSRA will then consider feedback and expects to publish the amendments shortly after the consultation period closes, and firms are told not to act on the proposals until the rules are formally amended.

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