ADGM FSRA Regulation of Virtual Asset Activities in ADGM

The framework regulates virtual asset activity through existing financial services permissions and activity-specific FSRA approvals. At present, the guidance identifies virtual asset regulated activities as dealing in investments as principal, dealing in investments as agent, advising on investments or credit, arranging deals in investments, managing assets, providing custody, and operating a multilateral trading facility. Chapter 17 of the Conduct of Business Rulebook applies to Authorised Persons conducting virtual asset regulated activities, with additional requirements for MTF operators and virtual asset custodians.

• Authorisation and permissions: Firms conducting virtual asset regulated activities in or from ADGM must hold the relevant FSP and satisfy applicable FSMR and FSRA rulebook requirements.
• Accepted Virtual Assets: Authorised Persons may conduct a virtual asset regulated activity only with an Accepted Virtual Asset. The 2025 guidance shifts the assessment to the Authorised Person, requires notification to the FSRA no later than five business days before use, and requires a public list of Accepted Virtual Assets used by the firm.
• Risk controls: The framework addresses AML/CFT and sanctions, consumer protection, technology governance, exchange-type activities, and custody. The guidance highlights controls for wallets, private keys, origin and destination of virtual asset funds, security, risk management, settlement, transaction recording and custody reconciliation.

The June 2025 version gives detailed criteria for assessing an Accepted Virtual Asset. Those criteria include traceability and monitoring, security, market profile, exchange connectivity, distributed ledger infrastructure and ecosystem, innovation or efficiency, and practical functionality. The guidance also expects governance arrangements, recordkeeping and continuous monitoring so that an asset continues to satisfy the relevant criteria.

Market conduct rules apply where Accepted Virtual Assets are admitted to trading on an MTF. The guidance states that ADGM’s market abuse provisions cover market abuse behaviour relating to Accepted Virtual Assets traded on an MTF, requires transaction reporting by MTFs, and applies misleading-statement provisions to Accepted Virtual Assets. MTFs are also expected to maintain exchange-like controls such as market surveillance, fair and orderly trading processes, settlement processes, transaction recording, rulebooks and transparency mechanisms.

ADGM launched its original crypto asset regulatory framework on June 25, 2018, covering spot crypto asset activities by exchanges, custodians and other intermediaries. The terminology and framework have since evolved, including the shift from “crypto assets” to “virtual assets,” later updates to the guidance, and 2025 amendments focused on Accepted Virtual Assets, capital requirements, fees, product-intervention powers, privacy tokens and algorithmic stablecoins.

As of June 16, 2026, the June 10, 2025 Rulebook version remains the relevant profile baseline identified for this law page. Editors should separately track related ADGM developments, including the FSRA’s April 29, 2026 announcement finalising a framework for virtual asset staking, because those developments may affect related rulebook obligations even where the core virtual asset guidance page is unchanged.