ADGM Crypto Exchange Licence: Operating a Virtual Asset MTF
A crypto exchange in Abu Dhabi Global Market is authorised by the FSRA to operate a Multilateral Trading Facility (MTF) using virtual assets. The FSRA expects exchange-grade market surveillance, custody arrangements and technology governance alongside a strong AML/CFT programme. VAF Global prepares the compliance framework for your MTF application.
Who needs this licence?
- Crypto exchanges choosing Abu Dhabi as their base
- Institutional virtual asset trading venues
- Platforms matching multiple buyers and sellers of virtual assets
Key elements of an ADGM MTF
Operating an MTF
Running a venue that brings together multiple buyers and sellers of Accepted Virtual Assets.
Custody
An MTF that holds client assets, or uses a third-party custodian while remaining responsible to clients, is Providing Custody and needs that permission, kept separate from the MTF.
Market integrity
Surveillance, fair and orderly trading, and market abuse prevention.
Technology governance
Cybersecurity, resilience and independent technology audits.
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 six months' operating expenses plus a buffer of up to six more months, held in fiat
- Market surveillance systems and market abuse controls
- Admission-to-trading rules and asset due diligence
- Client asset segregation and custody arrangements
- Exchange technology, cybersecurity and resilience
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 Exchange (MTF) Licence: FAQ
Should I choose ADGM or VARA for a crypto exchange?
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Both are established regimes. The choice depends on your clients, team location, banking relationships and business model. We help you compare the two before you apply.
What are Accepted Virtual Assets?
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An Accepted Virtual Asset is one the firm has assessed against the FSRA's criteria (including traceability, security, market profile, exchange connectivity and the underlying DLT) and notified to the FSRA at least five business days before use. Firms must publish their list of Accepted Virtual Assets, and privacy tokens and algorithmic stablecoins are prohibited.
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.