AML Requirements for Company and trust service providers in ADGM
Firms forming companies for clients, acting as director, secretary, trustee or nominee shareholder, or providing registered office and administrative services.
Are company and trust service providers designated in ADGM?
Yes. The designation follows the business itself, so a firm carrying on this activity in ADGM is within the regime without any further test.
- Designating provision
- ADGM AML Rulebook, DNFBP definition (f)
- Supervisor
- ADGM Registration Authority
Because the test turns on the firm's own activity, the free scope check puts the question that decides it and states the answer with the provision behind it.
Reports filed with no suspicion required
No threshold-based report has been established for this sector in ADGM. Reporting here is suspicion-driven: suspicious transaction and activity reports are filed when the firm has grounds to suspect, whatever the amount. That is not the same as saying nothing is owed, and it is why record keeping and the ability to recognise a suspicion matter more in this sector than any threshold.
What the regime requires here
ADGM Anti-Money Laundering and Sanctions Rules and Guidance (AML), made by the FSRA under the Financial Services and Markets Regulations 2015 governs AML in ADGM. Every designated firm owes the same spine of obligations: a documented risk assessment covering money laundering, terrorist financing and proliferation financing; customer due diligence with enhanced measures for higher risk and for high-risk countries; policies approved by senior management; a compliance officer at management level; an independent audit of the controls; immediate implementation of targeted financial sanctions; staff training; and records available to the authorities on request.
- ADGM Anti-Money Laundering and Sanctions Rules and Guidance (AML)
- ADGM Financial Services and Markets Regulations 2015
What Federal Decree-Law No. 10 of 2025 changed sets out the obligations and the penalties in full, with each article cited.
See where this firm actually stands
AML Compass assesses a company and trust service provider against the duties that apply in ADGM, scores its risk and inspection readiness, and produces a report of the gaps citing the provision behind each one.
The same sector elsewhere in the UAE
The designation, the threshold and the supervisor are not the same across jurisdictions, so a firm operating in more than one needs both answers.
This page summarises published legislation and rulebooks for general information. It is not legal advice, and it does not replace the texts themselves or guidance from your supervisor.