AML Requirements for Dealers in high value goods in ADGM
ADGM businesses buying or selling any item priced at or above USD 15,000, such as vehicles, vessels, art, antiques, jewellery, watches or commercial equipment.
Are dealers in high value goods 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 (c)
- Supervisor
- ADGM Registration Authority
A dealer in any saleable item priced at or above USD 15,000. This category exists here and nowhere else: the federal regime designates dealers in precious metals and stones and nothing broader, and the DIFC does not designate it either.
Reports filed with no suspicion required
- Cash at or above USD 15,000 with an individual
- Any transaction at or above USD 15,000 with an entity, whether in cash or by wire transfer
ADGM AML Rulebook, rule 8.1.1(7)(a)
These are not risk-based. They are due whenever the trigger is met, even where due diligence is complete and nothing looks wrong, which is why an unfiled one is a strict-liability gap rather than a judgement call.
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 dealers in high value good 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.
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.