The updated assessment gives ADGM a more detailed picture of financial crime risks across different legal structures, including how those risks may change as jurisdictions grow in size, complexity and international activity.
Growth brings closer scrutiny
The 2026 update revises ADGM’s first risk assessment of legal entities and arrangements, which was issued in March 2024. The regulator said the expansion of the LPA population has a direct impact on risk exposure, supervisory priorities and enforcement focus.
The assessment is consistent with the UAE National Risk Assessment and provides an ADGM-specific view of money laundering and terrorist financing risks. It is designed to support licensing decisions, ongoing monitoring, inspection planning, thematic supervisory work and enforcement actions where warning signs are identified.
The review also aims to help financial institutions, company service providers, virtual asset service providers and other regulated firms assess customer risk more effectively.
The risk profile remains stable
The ADGM said the overall money laundering and terrorist financing risk profile of legal entities and their arrangements remains broadly stable compared to the 2024 assessment.
The updated review reflects the latest national intelligence in the UAE National Risk Assessment, while also taking into account stronger controls within the ADGM. These include improvements in beneficial ownership transparency, closer oversight of gatekeepers, increased inspection activity and broader enforcement tools.
Changes in individual risk assessments should be read as the result of more accurate analyses, the regulator said, rather than a weakening of controls or a major change in the underlying risk environment.
“The 2026 update of our LPA Risk Assessment reflects a rigorous, evidence-based approach to identifying and mitigating money laundering and terrorist financing risks across our ecosystem,” said Ahmed Jasim Al Zaabi, Chairman of ADGM. “Through this work, ADGM continues to support a strong, transparent and resilient financial center underpinned by strong regulations and effective international cooperation.”
The update comes as international financial centers face closer scrutiny over beneficial ownership, corporate transparency and the use of complex structures to move or hide funds.
Tool for firms and supervisors
The ADGM said the assessment is an operational tool used in day-to-day regulatory work.
Its findings will guide incorporation and commercial licensing applications, reviews of existing entities, inspection priorities and targeted enforcement activity.
The document will also help firms engaging with legal entities and ADGM arrangements to calibrate due diligence, identify higher risk structures and assess behaviors that may require enhanced controls.
Nivetha Dayanand is Assistant Business Editor at Gulf News, where she spends her days unpacking money, markets, aviation and the big changes shaping life in the Gulf. Before returning to Gulf News, she launched Finance Middle East, complete with a podcast and video series. Her reporting has taken her from breaking news to feature-length shows and high-profile interviews. Nivetha has interviewed Prince Khaled bin Alwaleed Al Saud, Indian ministers Hardeep Singh Puri and N. Chandrababu Naidu, the IMF’s Jihad Azour, and a long list of CEOs, regulators and founders who are reshaping the region’s economy. An Erasmus Mundus journalism alum, Nivetha has shared classrooms and newsrooms with journalists from more than 40 countries, which perhaps explains her weakness for data, context and a good follow-up question. When she’s away from her keyboard (AFK), you’ll most likely find her at the gym with an Eminem playlist, enjoying One Piece, or exploring games on her PS5.
