ADGM Crypto Broker-Dealer Licence
Crypto brokers, OTC desks and dealers in ADGM need FSRA permissions such as Dealing in Investments (as principal or agent) and Arranging Deals in Investments for virtual assets. The FSRA expects strong conduct of business, client asset protection and AML/CFT. VAF Global prepares the compliance framework for broker-dealer applicants.
Who needs this licence?
- OTC crypto desks
- Crypto brokerage platforms
- Liquidity providers dealing as principal
- Firms arranging virtual asset transactions for clients
Relevant FSRA permissions
Dealing in Investments as Principal
Trading virtual assets against your own book with clients.
Dealing in Investments as Agent
Executing virtual asset trades on behalf of clients.
Arranging Deals in Investments
Bringing about or facilitating client transactions.
Advising on Investments or Credit
Often combined with brokerage where advice is given.
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
- Client classification and appropriateness or suitability procedures
- Best execution and conflicts of interest policies
- Client money and client asset rules
- Risk warnings and disclosures for virtual assets
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 Broker-Dealer Licence: FAQ
Is the ADGM broker-dealer route an alternative to VARA?
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Yes. Firms can choose to base a virtual asset brokerage in ADGM under the FSRA rather than in Dubai under VARA. See our VARA broker-dealer guide to compare.
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.