ADGM Investment Advisory License and ADGM Insurance Advisory License

Category 4

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Get your hands on Abu Dhabi Global Market’s Category 4
  • ADGM Investment Advisory License
  • ADGM Insurance Advisory License

In order to obtain this ADGM Category 4 license, you must apply for authorisation from the Financial Services Regulatory Authority (FSRA).

The FSRA is the independent regulator responsible for the authorisation, supervision, and ongoing oversight of all financial services firms operating within the ADGM. Therefore, an FSRA Investor Advisory Approval is required before you carry out your operations.

Scope of ADGM Category 4 License

Arranging deals in investment

Arranging deals in investments involves introducing clients to counterparties or facilitating transactions relating to securities or other regulated investments, without acting as principal or holding client money or assets.

Arranging custody services

Arranging custody services involves introducing clients to authorised custodians for the safekeeping of investments, without holding or controlling client assets.

Advising on financial products

Advising on financial products involves providing professional guidance to clients on the merits, risks, and suitability of regulated financial products, without executing transactions or holding client assets, in accordance with the requirements of the Financial Services Regulatory Authority (FSRA).

Insurance intermediation and insurance management

Insurance intermediation and insurance management involve advising on, arranging, or managing insurance policies and related services for clients, without underwriting risk, in compliance with the requirements of the Financial Services Regulatory Authority (FSRA).

Providing fund administration

Providing fund administration involves delivering administrative and operational support services to investment funds, including record-keeping, reporting, and investor servicing, without exercising investment discretion or holding fund assets, in accordance with the requirements of the Financial Services Regulatory Authority (FSRA).

Providing trust services (other than express trusts)

Providing trust services (other than express trusts) involves offering fiduciary or administrative services in relation to trust-like arrangements, excluding the establishment or management of express trusts, in accordance with the requirements of the Financial Services Regulatory Authority (FSRA).

Operating alternative trading systems or crowdfunding platforms (subject to additional approvals)

Operating alternative trading systems or crowdfunding platforms involves facilitating the matching of investors and issuers through electronic platforms for investment purposes, subject to specific authorisations and regulatory approval from the Financial Services Regulatory Authority (FSRA).

Arranging credit and advising on credit

Arranging and advising on credit involves introducing clients to lenders and providing advisory guidance on credit facilities and financing structures, without providing the credit or holding client funds, in accordance with the requirements of the Financial Services Regulatory Authority (FSRA).

Arranging or advising on money services

Arranging or advising on money services involves introducing clients to authorised money service providers or providing advisory guidance on payment, remittance, or related money services, without handling client funds or executing transactions, in line with the requirements of the Financial Services Regulatory Authority (FSRA).

The Financial Services Regulatory Authority (FSRA) will classify all investment advisory, credit advisory, and insurance advisory services as category 4 for licensing and monitoring purposes.

An ADGM Category 4 licence permits firms to:

  • Provide investment advisory services
  • Deal exclusively with Professional Clients

Firms may also apply for a Retail Endorsement, either: During the initial licensing process, or post-authorisation, subject to regulatory approval and enhanced compliance requirements.

ADGM Advisory License Cost: Capital Requirements

The minimum base capital requirement for a Category 4 Investment Advisory licence is: USD 10,000

The FSRA determines the actual capital requirements which will differ according to

1
The nature and scope of expected activities
2
The anticipated volume of transactions
3
The expected annual operating costs
4
The firm's risk profile and financial model
The firm will be required to maintain its capital at all times to meet the prudential standards set by the FSRA

Why Choose ADGM for Financial Advisory Services

ADGM provides finance advisory businesses with certain advantages, including


Familiar legal structure: Common law legal system, which is well known to international players

Robust regulatory standards and guidelines applying global best practice

English Language: Legal and Court Systems

Strategic Location within the GCC and MENA Region

A diverse financial infrastructure with banks, exchanges, and investment funds, among other fintechs

These characteristics make ADGM an attractive option for investment advisors and wealth management companies that seek comprehensive, reliable, effective, and internationally recognized regulatory cover.

Is the Category 4 Investment and Insurance Advisory License Right for You?

The ADGM Category 4 license can be suitable for businesses whose business model is more focused on providing investment, credit or insurance advice than on executing transactions.


The following scenarios may indicate that you would benefit from the Category 4 approval process:

You provide your clients with investment, credit, and/or insurance advice

Your client’s direct instructions are managed on a non-discretionary basis

You do not hold client money or other assets

You provide advice to professionals (and/or are seeking to provide financial services to retail customers in the future)

You would like to establish a regulated presence in the ADGM with an appropriate degree of compliance burden; or

You intend to establish a regional or cross-border advisory office within the UAE.

Category 4 Is Not Suitable If You

1

Intend to manage portfolios on a discretionary basis

2

Execute trades or deal in investments as principal or agent

3

Hold client funds or custody assets

4

Operate or manage collective investment funds

How to Get Investment Advisory License from ADGM?

Applying for an investment advisory license in ADGM is a structured process. Though the detailed requirements differ based on the firm structure and activities, the general steps are as follows:

1
Consultation Before Application

Engage early with Finjuris or any other legal counsel for a regulatory assessment of:

  • Distinguishing between the specific advisory permissions needed
  • Identifying the capital and governance requirements
  • Mapping compliance obligations

Early consultation may significantly smooth the application process and reduce regulatory queries.

2
Preparation and Submission of Application

With a lot of detail, collect and send to the FSRA:

  • Corporate documents: MOA, AOA, shareholder details
  • Business plan and financial projections
  • Compliance manuals and risk frameworks
  • CVs and background information on key personnel

A good application cuts down on the regulator back-and-forth and speeds up approval.

3
Regulatory Review

The FSRA measures:

  • Fit and Proper Status of Key Individuals
  • Financial viability of the firm
  • Adequacy of Policies and Procedures
  • Operational/ compliance readiness

The process also entails background checks, audits, and possibly interviews.

4
Licence Grant and Incorporation

On the completion of the review, the FSRA will issue an ADGM financial advisory licence, which will allow the firm to operate within the free zone. After the license:

  • Register the legal entity with the Registration Authority
  • Obtain secure physical office space
  • Implementation of compliance systems
5
Ongoing Compliance and Reporting

Post-licence, advisory firms have to:

  • Submitting periodical regulatory returns
  • Comply with AML/CFT rules
  • Maintain Capital and Governance Requirements
  • Undergo FSRA supervision and audits

Failure to comply can result in a fine, restricted licence, and/or licence revocation.

How Finjuris Assists Your Licensing Process

Finjuris provides end-to-end advisory support for firms seeking ADGM Category 4 License authorisation, including:

  • Regulatory strategy and activity scoping
  • FSRA application preparation and submissions
  • Financial modelling and capital planning
  • Entity structuring and ADGM incorporation
  • Ongoing compliance and post-licensing support
Clear process. Clean structure. Fully regulated outcomes.