Obtaining ADGM Category 3C License | FSRA Category 3C Financial Licensing

July 14, 2021by Mohammed Rahali

Obtaining ADGM Category 3C License | FSRA Category 3C Financial Licensing

Abu Dhabi Global Market (ADGM) is a broadly based recognized and renowned international financial center serving local, regional and international institutions. The ADGM serves in the obtainment of Financial License Categories 3C, 1, 2, 3A, 3B, 4 & 5.



An ADGM Category 3C Authorised Firm in this category may be licensed to carry on one or more Financial Services of Managing a Collective Investment Fund, Managing Assets, Providing Trust Services as a trustee of an express trust, Providing Custody (other than for a fund) and Managing a Profit Sharing Investment Account (received on a restricted basis). An Authorised Firm that has a 3C licence can also provide Financial Services in Category 4 but cannot provide Financial Services in Categories 1, 2, 3A or 3B.

  • Base Capital – US$ 500,000
  • Base capital requirement 3C Fund Manager – US$ 140,000 (to manage a Public Fund US$ 70,000 to manage exempt funds/QIFs).
  • Expenditure based capital requirement of 18/52 of annual operating expenditure (as the Fund Manager will hold or control Client Money)
  • Capital Plan must be captured in Internal Capital Adequacy Assessment Process Report.

Note that additional capital requirements may be imposed by FSRA on the review of the application.



  • Directors (at least 2, preferably 3-4) – can be outsourced (NEDs).
  • Senior Executive Officer (SEO) – In-house, UAE resident (can be a Director).
  • Risk Officer (RO) – can be outsourced.
  • Finance Officer (FO) – can be outsourced (can also be an Executive Director/Senior Manager).
  • Money Laundering Reporting Officer (MLRO) – can be outsourced, UAE resident (can be a CO).
  • Compliance Officer (CO) – can be outsourced, UAE resident (can be an MLRO).



  • Introduction to the Regulator
  • Draft of Regulatory Business Plan (RBP) (Application Forms, Business flow processes & charts)
  • Preparation of Financial model for 3 years and draft of ICAAP and IRAP report.
  • Preparation of policies and manuals (Compliance, AML, Risk Management, Remuneration, Governance, Conflicts of Interests, Business Continuity Plan etc.)

AUT – CORE: this form must be submitted by all applicants applying for a license to carry out one or more financial services in or from ADGM. It covers information on the applicant, its activities, prospective clients and controllers;

AUT – IND: this form must be submitted by the individuals holding a mandatory function including directors, senior executive officer, finance officer, compliance officer and money laundering reporting officer; and

AUT-AMS: this form must be submitted by applicants applying to conduct financial services relating to arranging credit or deals in investment. The applicant will be required to submit this form as one of the Proposed Activities of ADGM CO, including arranging credits and investment deals.

  • Draft of regulatory application for the company and individuals
  • Submission of Regulatory Application (with Policies and appointment of SEO, FO, MLRO, RO, CO)
  • Provision of full-time functions

SEO – Senior Executive Officer

FO – Finance Officer

RO – Risk Officer

MLRO – Money Laundering Reporting Officer

CO – Compliance Officer Initiation of the entity incorporation process

  • Office lease
  • Introduction to the UAE Bank for opening an Account
  • Issuance of Regulator’s financial services license


Wincore Advisory Group helps businesses to articulate their objectives and aspirations to set up an ADGM Category 3C Financial License. Contact us at [email protected] or +971 4 221 2602.




Mohammed Rahali

Managing Partner

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