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ADGM: 1 day ago
ADGM has published the 2026 update of its Money Laundering and Terrorist Financing (ML/TF) Risk Assessment of Legal Persons and Arrangements (LPA), representing a comprehensive revision of the assessment first issued in March 2024.
The updated assessment provides a detailed and jurisdiction‑specific understanding of ML/TF risks associated with the LPA available in ADGM and forms a key component of ADGM’s risk‑based regulatory, supervisory and enforcement framework.
Since the publication of the 2024 assessment, ADGM has experienced significant growth in scale and complexity, necessitating a refreshed and more granular reassessment of ML/TF risks.
The number of LPAs operating in ADGM has increased to 12,302 at the end of March 2026, compared to 7,173 at the time of the previous risk assessment in March 2024, representing a growth of approximately 72%. This expansion has a direct impact on overall risk exposure, risk prioritisation and supervisory focus, requiring ADGM to reassess whether existing vulnerabilities, mitigants and risk scores remain appropriate as the jurisdiction continues to scale.
The 2026 update also reflects the developments introduced at the national level since the last assessment, including updates to the UAE National Risk Assessment (NRA).
National Alignment and Purpose
The assessment supplements and supports the UAE NRA, providing an ADGM‑specific view of ML/TF risks across different legal structures and contributing to a coherent national understanding of financial crime risk.
Within ADGM, the findings are used to inform:
Key findings
The 2026 assessment indicates that the overall ML/TF risk profile of ADGM LPA remains broadly stable compared to the 2024 assessment.
While the threats component has been updated to reflect the latest national intelligence set out in the UAE NRA, this has largely been offset by strengthened mitigants within ADGM. These include enhancements to beneficial ownership transparency, strengthened supervision of gatekeepers, increased inspection activity, and expanded enforcement tools.
Changes in risk ratings should be understood as reflecting greater analytical precision and granularity, rather than a deterioration in controls or a fundamental change in underlying risk exposure.
H.E. Ahmed Jasim Al Zaabi, Chairman of ADGM, said, “ADGM remains firmly committed to safeguarding the integrity and transparency of its jurisdiction aligned with UAE National priorities as it continues to grow in scale and complexity. We believe clarity on risk is fundamental to how financial centres sustain trust, enable growth, and maintain global competitiveness. The 2026 update of our LPA Risk Assessment reflects a rigorous, evidence-based approach to identifying and mitigating money laundering and terrorist financing risks across our ecosystem. Through this work, ADGM continues to support a robust, transparent and resilient financial centre, underpinned by strong regulation and effective international cooperation.”
The assessment is a practical, operational tool embedded in ADGM’s day‑to‑day regulatory work. It also serves as a reference point for financial institutions, company service providers, virtual asset service providers, designated non‑financial businesses and professions, and other stakeholders engaging with ADGM LPA, helping them to calibrate customer due diligence and identify higher‑risk structures and behaviours.
The publication of the 2026 assessment reinforces ADGM’s standing as a leading international financial centre, committed to financial integrity, transparency and the effective prevention of money laundering and terrorist financing.
The full 2026 ML/TF Risk Assessment of ADGM Legal Persons and Arrangements (LPA) is available on the ADGM website HERE.
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