The Abu Dhabi Global Market (ADGM) has enacted the Administrative Regulations 2025, significantly overhauling its framework for investigation, supervision, and enforcement. Published on October 28, 2025, these Regulations establish a comprehensive and modern system designed to bolster compliance and market integrity across all ADGM commercial legislation. The Regulations introduce a two-tier contravention system, detailed notice and appeal processes, robust investigation powers (including skilled person appointments and compulsory interviews), and an expanded suite of enforcement tools ranging from fines and censure statements to licence variation, suspension, and cancellation.
Key Features of the Regulations
The new framework introduces robust procedures and an expanded set of tools, focusing on accountability and efficiency:
- Two-Tier Contravention System:
- Tier 1: Standard fines of up to USD 2,000.
- Tier 2: Permits fines up to USD 54,000,000, with escalation for repeat breaches within 12 months, alongside a wider range of enforcement tools.
- Enhanced Investigative Powers: The Registration Authority can now:
- Compel the production of information and documents from entities and connected parties.
- Appoint skilled persons to report on or rectify data issues.
- Appoint investigators with powers to compel interviews and on-site access, while preserving legal privilege subject to limited exceptions.
- Stronger Supervisory and Exceptional Intervention:
- The Authority can issue immediate Supervisory Notices to impose requirements or vary licences.
- In exceptional cases involving serious contraventions, criminality, or imminent harm, the CEO can immediately suspend, restrict, or cancel licences, or issue prohibition orders.
- Clear Procedural Safeguards: The Regulations prescribe structured processes for notices (Financial Penalty, Warning, Decision), ensuring access to material and opportunities for representation (written and, by notice, oral). Judicial review is available in the ADGM Courts.
- Settlement Mechanisms: The Authority is empowered to enter settlement discussions at any stage and accept enforceable undertakings with court-enforceable remedies for non-compliance.
Purpose and Practical Implications for ADGM Entities
The Regulations are designed to uphold market integrity, protect users, deter unlawful activities, and promote accountability.
How can Al Tamimi help?
Al Tamimi & Company’s Corporate Structuring and Litigation teams possess deep expertise in ADGM regulatory affairs and enforcement. We can help your organisation navigate this new landscape effectively by:
- Conducting a Gap Analysis and Compliance Audit: We can assess your current policies and procedures against the new Regulations, identifying key risk areas and necessary adjustments to ensure full compliance with the two-tier contravention system and information-gathering requirements.
- Drafting and Updating Policies: Assisting in the formulation of updated compliance policies, including clear protocols for investigation cooperation, handling of privileged material, and response to Supervisory and Exceptional Notices.
- Training and Preparation: Providing tailored training for key personnel on the new notice processes, investigation protocols, and the management of sensitive/privileged materials to ensure a smooth and legally sound response to any Authority request.
- Strategic Representation and Advice: Offering strategic advice and representation in the event of an investigation, information request, or enforcement action (including settlement discussions or judicial review), leveraging our in-depth knowledge of ADGM Court procedures and regulatory expectations.
Key Contacts
For a deeper understanding on the regulations or to learn more about our services offering, kindly reach out to Izabella Szadkowska I.Szadkowska@tamimi.com; Nour Srour N.Srour@tamimi.com or any member of the Corporate Structuring team.