The Abu Dhabi Global Market (ADGM) Registration Authority (RA) has published three critical reports revealing key findings from 2024 and outlining supervisory priorities through 2026.

These insights are essential for DNFBPs (Designated Non-Financial Businesses and Professions) committed to strengthening their AML/CFT and TFS frameworks. Solutions like Ascent’s One Constellation platform can play a critical role in streamlining this compliance work.

 

1. Key Findings from 2024 Onsite Assessments

Based on 32 inspections across DNFBPs—including company service providers, legal consultancies, auditors, and dealers in high-value goods—the RA identified important compliance gaps.

  • Inadequate Enhanced Due Diligence (EDD): Weak verification of source of funds/wealth and lack of senior management approval for high-risk clients.
  • Gap in Business Risk Assessments: Many firms failed to evaluate Terrorism Financing (TF) and Proliferation Financing (PF) risks.
  • Missing Annual AML/TFS Reviews: Some DNFBPs have not conducted required periodic assessments.
  • Weak Ongoing Monitoring: Ineffective systems for continuous customer screening, with failures to flag transactions over AED 55,000.
  • Lack of KYC Certification: Use of uncertified ID documents was widespread.
  • Insufficient MLRO Succession Planning: Many firms lacked formal transition procedures or notification to the RA.

📄 Common Findings Report – 2024 Onsite Assessments

 

2. Insights from the Thematic Review

In a widespread review involving 202 DNFBPs and 20 in-depth firm examinations, the RA flagged issues in:

  • Generic Risk Methodologies: Many approaches were not tailored to the firm’s specific context.
  • Poor Differentiation of ML/TF/PF Risks: Risk assessments often failed to distinguish between different categories.
  • Deficient Suspicious Activity Reporting (SAR): Processes lacked clarity around confidentiality and escalation protocols.
  • Non-Specific AML Training: Many programs were overly broad and lacked role-based or TF/PF focus.

📄 Thematic Review – Business Risk Assessment & SAR/STRs

 

3. Regulatory Priorities 2025–2026

The RA has laid out nine supervisory priorities, with Priority 7 aiming to:

“Deliver effective supervision of ADGM-licensed DNFBPs to promote high standards of AML and TFS compliance.”

This signals a shift toward more structured inspections, stakeholder outreach, and enforcement where firms fall short. Broader priorities touch on areas like beneficial ownership, audit quality, emerging technologies, and regulatory enforcement.

📄 Regulatory Priorities Report 2025–2026

 

4. What DNFBPs Should Do Now

In response to these findings and supervisory signals, DNFBPs should:

  • Conduct a detailed self-review and implement corrective actions within 3 months.
  • Update AML/TFS policies regularly to align with evolving regulatory expectations.
  • Put in place MLRO succession plans, tailored training, and robust monitoring mechanisms.

At The Ascent Group, we see these RA reports as a practical roadmap—not just a compliance checklist. Through our One Constellation fintech solution, DNFBPs in ADGM can streamline their AML processes, risk assessments, and transaction monitoring within one integrated platform.

If you’d like expert guidance in interpreting the RA’s expectations or enhancing your compliance framework, we’re here to help.

 

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