ADGM Asset Management License and ADGM Fund Management License

Category 3C

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An ADGM Asset Management License and ADGM Fund Management License (ADGM Category 3C Licence) issued by Abu Dhabi Global Market (ADGM) enables firms to provide regulated asset management, fund management, restricted profit-sharing account management, trust services and custody (non-fund) activities under the supervision of the Financial Services Regulatory Authority (FSRA).

An ADGM Asset Management License and an ADGM Fund Management License, through the ADGM Category 3C License structure, allows asset managers to conduct regulated investment and fund management activities in one of the world’s most advanced financial hubs. Under the regulatory supervision of the Financial Services Regulatory Authority (FSRA), the license gives asset managers regulatory credentials, operational freedom, and access to global investors.

ADGM Investment Management Licence

The ADGM investment management license is meant for licensees that manage assets, portfolios, and collective investment funds. This includes discretionary portfolio managers, fund sponsors, boutique asset managers, and family offices with an investment arm.

Finjuris helps clients structure, prepare and secure ADGM Category 3C License approval with regulatory clarity and operational confidence.

What Is an ADGM Asset and Fund Management (Category 3C) Licence?

An ADGM Category 3C license allows qualified companies to engage in several regulated financial services that lie between advisory/brokerage and full custody or credit offering. This licence category is specifically structured to accommodate professional asset and fund managers that require discretion over client assets while operating under strict regulatory safeguards. Under an ADGM Asset Management License or ADGM Fund Management License, firms may be authorised to carry out one or more of the following regulated activities:

  • Managing a collective investment fund
  • Managing assets for clients
  • Managing a Profit-Sharing Investment Account (PSIA) received on a restricted basis
  • Providing trust services (as trustee of an express trust)
  • Providing custody services (other than for a fund)

An ADGM Category 3C license thus fills the gap between basic asset and fund management and client servicing, allowing companies to expand their managed portfolios or fund arrangements within the clear legal and regulatory environment provided by ADGM.

Why Choose Category 3C?

Category 3C is best suited for companies that aim to

VARA License

Be recognized as regulated asset managers or fund managers

VARA License

Handle client assets in a manner protected by FSRA regulations

VARA License

Engage in trust and restricted PSIA business

VARA License

Offer custody services that are not exclusively linked to a fund

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Enjoy flexibility in asset management and client servicing lines of business

This category of license is most suitable for boutique asset managers, fund sponsors, discretionary portfolio managers, family offices with investment arms, and companies providing structured asset services.

ADGM Category 3C License: Who Is It For?

The ADGM Category 3C License is ideally suited for firms that intend to operate as professional asset or fund managers without engaging in deposit-taking or credit provision. Common applicants include:

Asset management firms managing client portfolios

Fund managers launching public, exempt, or QIF structures

Boutique investment firms and discretionary portfolio managers

Family offices managing pooled or segregated assets

Wealth management firms offering managed investment solutions

For firms seeking an asset manager license in ADGM, Category 3C offers a balanced regulatory structure that combines credibility with operational flexibility.

ADGM Fund Management License: Scope of Activities

An ADGM Fund Management License allows firms to establish and manage collective investment schemes within ADGM’s fund regime. These may include:

Public funds

Exempt funds

Qualified Investor Funds (QIFs)

Fund managers licensed under Category 3C are responsible for:

Investment decision-making

Portfolio construction and risk management

Valuation
oversight

Compliance with fund constitutional documents

Ongoing regulatory reporting to the FSRA

The FSRA fund management authorization ensures that fund managers operate under transparent governance, strong investor protection mechanisms, and internationally aligned standards.

ADGM Portfolio Management License

The ADGM portfolio management license permits firms to manage assets on a discretionary basis for individual or institutional clients. This includes making investment decisions, executing trades, and rebalancing portfolios in accordance with agreed mandates.

Portfolio managers must demonstrate:

Robust investment governance

Clear client mandate documentation

Strong risk management controls

Ongoing suitability and disclosure practices

The FSRA applies heightened scrutiny to discretionary portfolio management due to the fiduciary nature of the activity.

Regulatory and Capital Requirements

As Category 3C investment firms may be dealing with client money or assets, or managing funds, the regulator will apply prudential, governance, and risk standards commensurate with the business activities conducted.

Typical requirements are as follows: Base Capital: USD 500,000 (standard for asset/fund managing permissions) Lower Base Capital for fund manager business:

approx. USD 140,000 for public funds and USD 70,000 for exempt/QIFs (dependent on structure)

Capital plan as part of Internal Capital Adequacy Assessment Process (ICAAP)

Strong governance, risk, compliance, and AML arrangements

Essential operational policies aligned with asset/fund management and custody activities

The FSRA will evaluate actual capital and governance on a case-by-case basis, dependent on risk profile, asset exposure, and business activity.

Additional Regulatory Considerations Under the ADGM Category 3C License

While the ADGM Category 3C License is often viewed as a “standard” asset and fund management licence, the FSRA treats it as a substantive risk-bearing authorisation. Firms are expected to demonstrate maturity not just at the point of licensing, but on an ongoing basis.

Category 3C firms are subject to enhanced supervisory engagement, particularly where they:

  • Manage third-party client assets on a discretionary basis
  • Operate multiple funds or strategies
  • Have cross-border clients or delegated portfolio arrangements
  • Use complex investment instruments or leverage

The FSRA’s supervisory focus typically extends beyond formal compliance into governance effectiveness, investment discipline, and risk culture.

Client Classification and Investor Protection

Category 3C firms must correctly classify clients as:

Retail Clients

Professional Clients

Market Counterparties

This classification determines:

Disclosure obligations

Suitability assessments

Reporting frequency


Investor protection thresholds

The FSRA expects asset managers to maintain robust client onboarding frameworks, particularly where professional clients are based outside the UAE or where marketing is conducted cross-border.

How Finjuris Helps

Finjuris offers comprehensive advisory services for ADGM Category 3C license applicants from start to finish, including:

  • Analysis of licence category and scoping
  • Development of policy and documentation for FSRA approval
  • Design of governance structure
  • Preparation and submission of application
  • Handling of regulator queries and engagement
  • Support with post-licence compliance

Finjuris will make sure that your application is complete, compliant, and ready for success with the regulator.

Planning to Apply for an ADGM Category 3C Licence?

Speak to Finjuris to define your strategy, prepare your regulatory documentation and navigate the FSRA authorisation process with confidence.

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