ADGM's primary financial-services statute, modelled on the UK Financial Services and Markets Act 2000: it sets the powers, functions and objectives of the Financial Services Regulatory Authority, the general prohibition on regulated activities without authorisation, market abuse and enforcement, supplemented by the FSRA Rulebooks. Headline record only; the text is in the Thomson Reuters-hosted ADGM rulebook.
The Financial Services and Markets Regulations 2015 (FSMR) establish the legislative and regulatory framework for financial services in Abu Dhabi Global Market. They are the statute under which the Financial Services Regulatory Authority (FSRA) authorises, supervises and disciplines financial firms, and they define the perimeter that every non-financial ADGM entity must stay outside of. The ADGM portal describes FSMR as broadly modelled on the United Kingdom's Financial Services and Markets Act 2000 and related legislation.
According to the portal, FSMR contains provisions detailing the powers, functions and objectives of the FSRA, including authorisation, recognition, market infrastructure bodies, enforcement and information-gathering powers, accounting and auditing, listing and prospectuses, collective investment funds, settlement finality, disclosure of information and financial services transfers. FSMR is supplemented by the FSRA Rulebooks, which detail the requirements firms must meet after authorisation, and by a Guidance and Policies Manual.
FSMR sits on the foundation laid by Abu Dhabi Law No. 4 of 2013, which created the FSRA as the authority solely responsible for regulating financial services in ADGM (Article 12) and which prohibits any person from engaging in financial services, or any activity requiring a permit, licence or registration from an ADGM authority, without first obtaining it (Article 22(3)). FSMR gives that prohibition its detailed content: which activities are regulated, how a firm becomes authorised, what happens if it acts without authorisation, and what the regulator may do about market misconduct.
ADGM enacted its first set of commercial regulations on 3 March 2015. Under section 12(1) of the Interpretation Regulations, ADGM regulations come into force on the day specified in them or, where commencement is the date of publication, on the expiry of the day of publication; the portal states that the 2015 commercial regulations came into force on the expiry of the day of their respective publication. FSMR has been amended many times since 2015 and remains in force; the current consolidated text is published in the ADGM rulebook hosted by Thomson Reuters, which was not accessible for this record. The ADGM portal page read gives only the description above, so this record is a headline entry: it tells a business owner what FSMR does and when it matters, and the FSRA Rulebooks and the Controlled Activities Rules should be consulted before any activity that could be a financial service is started in or from ADGM.
Any person carrying on, or proposing to carry on, financial services in or from ADGM, including banks, asset and fund managers, brokers, advisers, insurers, market infrastructure bodies and virtual-asset firms, together with their auditors and issuers listing securities; it also marks the boundary that non-financial ADGM companies, SPVs and foundations must not cross.
| Part: Powers, functions and objectives of the FSRA (portal description) | FSMR sets out the powers, functions and objectives of the Financial Services Regulatory Authority as the regulator of financial services in ADGM, supplemented by the FSRA Rulebooks and a Guidance and Policies Manual. |
| Part: Authorisation and recognition (portal description) | FSMR contains the provisions on authorisation of firms and recognition of bodies, giving effect within ADGM to the prohibition in Article 22(3) of Law No. 4 of 2013 on financial services without a licence, permit or registration. |
| Part: Market infrastructure bodies, listing and prospectuses, collective investment funds (portal description) | FSMR regulates market infrastructure bodies, listing and prospectus requirements and collective investment funds, with settlement finality and financial services transfers also addressed in the Regulations. |
| Part: Enforcement and information-gathering powers (portal description) | FSMR gives the FSRA enforcement and information-gathering powers over the persons it regulates, together with provisions on disclosure of information. |
| Part: Accounting and auditing (portal description) | FSMR contains the accounting and auditing provisions that apply to authorised firms, which the FSRA Rulebooks then detail for firms after authorisation. |
The ADGM portal page read for this record does not state the sanctions under FSMR. At the level of the founding law, Article 23 of Abu Dhabi Law No. 4 of 2013 provides that a person carrying on commercial or financial activity contrary to that law or the ADGM regulations is liable to a fine of not less than AED 5,000 and not more than the higher of AED 50 million and 10% of the value of the relevant transaction, with administrative sanctions including notices, warnings and licence suspension or withdrawal.
Our ADGM clients are holding companies, SPVs and foundations that hold shares, property and intellectual property; none of them is an FSRA-authorised firm. FSMR matters to us as the perimeter. Before we file an incorporation we test the proposed activities against the Controlled Activities Rules and the FSRA framework so that a client who intends to manage third-party money, lend, issue tokens or advise on investments is told at the outset that those activities need FSRA authorisation and a different kind of application. We also watch for drift: an SPV that starts raising funds from outside investors, or a family holding company that begins managing money for relatives, can cross the line without anyone noticing. Where a client does need authorisation, we coordinate with a regulatory adviser rather than attempt the FSRA application ourselves.
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