Executive summary
This page provides an overview of crypto-asset transfer regulation and Travel Rule requirements applicable within Abu Dhabi Global Market (ADGM). It is intended for virtual asset service providers, financial institutions, and compliance teams operating in or interacting with the ADGM jurisdiction.
Abu Dhabi operates a dual-track regulatory model: while federal UAE authorities set overarching AML/CFT standards, the ADGM functions as an international financial centre with its own legal system and regulator. Within ADGM, Travel Rule obligations are embedded in a comprehensive virtual asset regulatory framework administered by the Financial Services Regulatory Authority.
This content is provided for informational purposes only and does not constitute legal advice.
Regulatory landscape overview
ADGM is widely regarded as one of the earliest and most comprehensive regulators of virtual assets globally. Its framework is grounded in English common law principles and aligned with Financial Action Task Force (FATF) standards.
Key features of the ADGM approach include:
Integration of Travel Rule requirements into a broader virtual asset regulatory framework
Alignment with UAE federal AML/CFT laws and international standards
Ongoing refinement of rules to address emerging activities such as stablecoins and staking
As of 2026, regulatory focus has expanded to cover fiat-referenced tokens and staking-related services, reflecting ADGM’s role as an institutional digital asset hub.
Supervisory and regulatory authorities
Travel Rule compliance in ADGM operates within a coordinated federal and free-zone structure:
Financial Services Regulatory Authority (FSRA): Sole regulator and supervisor for ADGM-licensed entities
National Committee for AML/CFT (NAMLCFTC): Sets overarching AML/CFT policy across the UAE
UAE Financial Intelligence Unit: Recipient of suspicious transaction reports and AML intelligence
ADGM requirements are designed to remain consistent with federal AML expectations while maintaining regulatory autonomy within the free zone.
Travel Rule status in Abu Dhabi (ADGM)
The Travel Rule is fully implemented and enforced for ADGM-licensed virtual asset service providers as part of the ADGM AML and Sanctions Rulebook.
Under the ADGM framework:
Travel Rule obligations apply to qualifying virtual asset transfers
Required information must accompany transfers above defined thresholds
A risk-based approach applies to higher-risk activities, including interactions with self-custodied wallets and complex transaction patterns
This positions ADGM among the most operationally advanced Travel Rule jurisdictions globally.
Timeline and key milestones
June 2018: ADGM launches its Virtual Asset Framework
2023–2024: Travel Rule implementation aligned across UAE jurisdictions
January 2026: Finalised rules for fiat-referenced tokens take effect
Q1 2026: Additional FSRA guidance clarifies AML and Travel Rule treatment of staking-related services
Thresholds and scope
ADGM applies the UAE federal threshold framework to virtual asset transfers.
Threshold: AED 3,500 (approximately USD 950)
Scope: Transfers above this threshold generally require the exchange of full originator and beneficiary information
Aggregation: Linked or structured transactions may be assessed collectively
Below-threshold transfers: Typically subject to basic information collection requirements
This approach balances proportionality with robust AML oversight.
Required data elements (high-level)
For in-scope transfers, ADGM rules generally require the transmission and retention of information relating to:
The originator, including identifying details and wallet or account identifiers
The beneficiary, including identifying details and wallet or account identifiers
Transaction-level identifiers supporting traceability
Specific data elements are defined in regulation and FSRA guidance, and must be made available to authorities upon request.
Local nuances and interpretive considerations
Several aspects of the ADGM framework are particularly relevant for compliance teams:
Fiat-referenced tokens: Stablecoin-linked activities are subject to enhanced disclosure and data-sharing expectations
Staking activities: Certain staking service models may be treated as regulated virtual asset activities for AML purposes
Technology-forward supervision: ADGM explicitly recognises blockchain analytics and technical controls as part of risk mitigation
These features reflect ADGM’s focus on institutional-grade compliance and supervisory transparency.
Self-custodied (unhosted) wallet considerations
ADGM applies a risk-based and technology-enabled approach to transfers involving self-custodied wallets.
Additional controls may apply for transfers above the applicable threshold
Firms are expected to apply enhanced monitoring and screening to higher-risk wallet interactions
Verification and due diligence measures are informed by transaction risk, customer profile, and available technical tools
This approach is more prescriptive than in some jurisdictions, reflecting ADGM’s supervisory expectations.
Cross-border and interoperability considerations
As a global financial centre, ADGM places particular emphasis on cross-border compliance and interoperability.
Key considerations include:
Assessing counterparty VASP readiness and data protection practices
Attempting to obtain required information for inbound transfers from less-regulated jurisdictions
Ensuring secure and timely information exchange without mandating a specific technical protocol
These expectations make interoperability and counterparty assessment central to ADGM compliance operations.
Indicative compliance readiness checklist
The following considerations are illustrative and non-exhaustive:
Appropriate ADGM Financial Services Permission covering virtual asset activities
Appointment of an approved Money Laundering Reporting Officer
Ability to apply threshold-based Travel Rule controls
Processes for assessing counterparty VASP risk
Record-keeping aligned with ADGM AML retention requirements