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

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 Category 3C Financial License ADGM. Contact us at or +971 4 443 6694.


DIFC and ADGM are the ones granting category 3C license

The required Individuals for a Category 3C Financial License ADGM are the ones carrying out Licensed Functions in an Authorised Firm such as the Senior Executive Officer, the Compliance officer, the Money laundering reporting officer, the Finance Officer, and the risk officer and other main persons who are essential to the business operations (Technology officer, portfolio, or investment managers).

Category 3C Financial License ADGM covers the following activities: Managing collective Investment Funds, Managing assets, Asset Management, Providing Trust services as a trustee of an express trust, Providing Custody, Managing a profit-Sharing Investment Account and Money Services Business Firms such as Payment Service provider (PSP) issuing Stored Value.

USD 500,000 is the base capital requirement for a ADGM category 3C license. However, The base capital requirement for a Category 3C Fund Manager would be USD 50,000, if it manages Exempt (EF) or Qualified Investor Funds (QIF). Actual capital required to conduct a Category 3C Financial License ADGM activity will depend on the nature, quantum of business and forecasted annual expenditure, as per the financial model of the proposed firm. Based on higher risks associated with the activities, the regulator may place higher entry-level requirements and restrictions on the license itself. Capital waivers may be available to the branch of a regulated financial institution having its head office in a recognized regulatory jurisdiction. The higher of the three components of capital for a category 3 B license is set to be the capital requirement: base capital, risk-based capital, and expense-based capital.

The Fund Manager under a ADGM category 3C, if approved, can manage domestic (Public, Exempt and Qualified Investor Funds) and Foreign Funds in other jurisdictions as well. In case the firm wishes to also engage in discretionary portfolio management services, it must go through a full-fledged license process.

Under a ADGM category 3 C license a Stored Value means any electronically (including magnetically) stored monetary value as represented by a claim on the issuer which is issued on receipt of funds or other assets for the purpose of making Payment Transactions.

Following the introductory call to the regulator, the Regulatory Business Plan (RBP) with 3 years financial projections are submitted to the regulator for review. Subjects to its comments, a full application with its annexes (including processes, policies, structure chart, KYC and AML supportive documentation, Key individuals’ KYC) are submitted for acceptance within 10 business days while the detailed review shall take a minimum of 2 months. During this period, exchanges are made with the applicant. Then after, an In-Principle approval, with the conditions to be fulfilled (such as incorporation, capitalisation, bank account opening, obtention of professional indemnity, rent of an office), is granted by the regulator in case the application is fully accepted. Once the conditions fulfilled, a final submission is made to the DFSA or FSRA for the regulator to issue the Financial Service Permissions under the ADGM category 3C license.

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Mohammad Rahali

Managing Partner

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

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