ADGM Crypto Asset Management Licence
Managing virtual asset portfolios or crypto funds in ADGM requires FSRA permissions such as Managing Assets or managing a collective investment fund. ADGM is often considered by crypto fund managers because of its common-law framework and established fund regime. VAF Global prepares the compliance framework for managers applying to the FSRA.
Who needs this licence?
- Crypto hedge funds and venture funds
- Discretionary virtual asset portfolio managers
- Family offices managing third-party virtual assets
Relevant FSRA permissions
Managing Assets
Discretionary management of client virtual asset portfolios.
Managing a Collective Investment Fund
Managing a fund that invests in virtual assets.
Advising on Investments or Credit
Advice on virtual asset investments, if offered.
Custody arrangements
Fund and client assets held with a suitably authorised custodian.
Key requirements
- An ADGM entity (a company, or a branch where permitted) with real substance in ADGM
- Approved Persons for the mandatory Controlled Functions, such as Senior Executive Officer, Compliance Officer and MLRO (UAE-resident)
- Regulatory capital as required by FSRA rules for the firm's activities
- AML/CFT and sanctions framework meeting FSRA rules and UAE federal requirements
- For virtual asset activities such as dealing, custody, managing assets and operating an MTF, only Accepted Virtual Assets: the firm assesses each asset against FSRA criteria and notifies the FSRA before use
- Investment mandates, valuation and NAV policies
- Conflicts of interest and allocation policies
- Custodian due diligence and oversight
- Investor disclosures and reporting
The licensing process
- 1
Pre-application discussions
Meetings with the FSRA, including technology demonstrations, to present your model and confirm the regulated activities.
- 2
Application
Submit the application, regulatory business plan, policies and approved-person forms.
- 3
Review
The FSRA assesses the business, people, controls and technology.
- 4
In-principle approval
Approval subject to conditions such as incorporation, capital and staffing.
- 5
Final approval and launch testing
Meet the conditions and receive the FSP; complete operational launch testing and third-party systems verification before going live.
How VAF Global helps
We prepare and run the compliance side of your licence, so your application meets the regulator's expectations from day one.
- Activity scoping and ADGM versus VARA comparison
- AML/CFT, KYC and sanctions policies for FSRA
- Compliance monitoring programme and risk assessments
- Approved-person readiness support
- Outsourced MLRO and compliance support, where permitted
- KYT transaction monitoring
ADGM Crypto Asset Management Licence: FAQ
Is ADGM good for crypto funds?
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ADGM has an established fund regime and a virtual asset framework, which makes it a common choice for crypto fund managers. The best jurisdiction depends on your investors and strategy.
Can one ADGM permission cover several activities?
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Yes. The FSRA's Financial Services Permission lists each regulated activity the firm may carry on, so firms often combine, for example, dealing, custody and an MTF. Capital and staffing requirements reflect the combined scope.
Other UAE licensing guides
Last reviewed October 2026. This guide is general information for compliance planning, not legal advice. Regulatory requirements change; always confirm current rules with the regulator. VAF Global is a compliance consultancy and does not provide legal services.