Abu Dhabi Global Market’s Registration Authority has moved again to sharpen its anti-money laundering and counter-terrorist financing framework, publishing a set of amendments to its commercial legislation that raise the bar on beneficial ownership disclosure, nominee transparency, and cash handling by regulated service providers. 

For entities operating in or considering ADGM, the message is consistent with where the jurisdiction has been heading for some time: transparency obligations are only going to get more granular, not less. Here is what changed, and what it means in practice. 

What the Amendments Cover?

The RA has introduced four targeted changes, effective immediately upon publication.

• Nominee status now goes on the public record: Where a shareholder or director is acting as a nominee, that fact will be reflected on the public register. This closes a gap that has historically made it harder for third parties – counterparties, banks, regulators – to see who is really standing behind a nominee arrangement, without requiring disclosure of the underlying principal itself.

• Trusts are now squarely in scope for beneficial ownership requests: The Registrar has been given explicit power to request beneficial ownership information relating to trusts connected to ADGM. Trust structures have often sat in a grey zone relative to corporate beneficial ownership rules; this amendment removes the ambiguity.

• Cash transactions face new caps for DNFBPs: Designated non-financial businesses and professions – legal, accounting, company service, and real estate businesses among them – are now subject to licensing conditions that prohibit accepting or distributing cash above prescribed thresholds. This lands directly on corporate service providers, law firms, and accountants operating in ADGM, including firms like ours.

• Branches inherit their parent’s disclosure burden: Registered branches of foreign legal persons in ADGM must now maintain and provide beneficial ownership information relating to their foreign parent entity, not just information about the branch itself.

Why This Matters Beyond Compliance Box-Ticking?

These amendments read as ADGM continuing to align itself with FATF-style international standards on beneficial ownership transparency, an area regulators across the UAE’s financial free zones have been converging on. For groups running multi-jurisdictional structures – a holding company in ADGM, a trust connected to it, a branch of a foreign parent – the practical effect is that beneficial ownership information now needs to be accurate, current, and defensible across every layer of the structure.

The nominee disclosure point deserves particular attention. Structures that use nominee shareholders or directors for legitimate commercial reasons – confidentiality preferences, succession planning, or operational convenience – will still be able to do so, but the nominee relationship itself will no longer be invisible on the public register. That changes the calculus for family offices and private clients who have relied on nominee arrangements as part of a broader confidentiality strategy; nominee status alone is no longer a shield from scrutiny, even if the underlying principal’s identity remains protected.

The cash transaction restriction is a narrower but immediate operational point for CSPs, accountants, and legal practices: internal payment acceptance policies need to be checked against the new thresholds now, not at the next audit cycle.

What Businesses in ADGM Should Do Now?

• Review nominee arrangements: If your structure uses nominee shareholders or directors, confirm how that status will now appear on the public register and whether any client communication is needed ahead of time.

• Audit trust-linked structures: Entities with trusts connected to ADGM should ensure beneficial ownership records are complete and readily producible if the Registrar exercises its new request powers.

• Check cash handling policies: DNFBPs should confirm internal processes don’t inadvertently breach the new cash payment thresholds.

• Map branch-parent disclosure: Foreign parents of ADGM-registered branches should have their beneficial ownership information organised and ready to flow through, rather than assembled reactively.

The full amended legislation is available via ADGM’s official legislation portal. As with previous rounds of AML-driven reform in ADGM, the direction of travel is clear — and getting ahead of it is considerably less costly than catching up after the fact.