ADGM Crypto Custody Licence (Providing Custody)
Safeguarding virtual assets for clients in ADGM requires an FSRA permission for Providing Custody. The FSRA focuses on how assets and private keys are protected, segregated and reconciled. VAF Global prepares the compliance and control documentation for custody applicants.
Who needs this licence?
- Institutional digital asset custodians
- Exchanges and brokers holding client assets in ADGM
- Custodians serving funds and asset managers
What custody covers
Safeguarding assets
Holding and administering client virtual assets.
Key management
Generation, storage and recovery of private keys.
Reconciliation
Regular reconciliation of client holdings with on-chain records.
Third-party custody
Using sub-custodians requires due diligence and oversight.
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
- Capital of the higher of USD 250,000 or six months' audited expenditure
- Key management and wallet security policies
- Segregation of client assets
- Reconciliation and client reporting
- Business continuity and incident response
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 Custody Licence: FAQ
Can an ADGM exchange hold client crypto itself?
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Only with a Providing Custody permission. An exchange that uses a third-party custodian but remains responsible to clients for their assets is still treated as Providing Custody, and custody operations must be kept separate from the MTF.
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.