ADGM Administrative Regs Overhaul - June 2025

The Riffle

ADGM’s Registration Authority (RA) is moving to streamline and strengthen its enforcement framework with the introduction of new overarching Administrative Regulations. The Consultation Paper No. 7 of 2025 proposes a comprehensive approach to sanctions, contraventions, procedural fairness, and more.

Why This Matters ?

Right now, enforcement rules are scattered across multiple legislations—confusing, inconsistent, and outdated. These proposals aim to:

• Centralize enforcement procedures

• Differentiate minor vs serious violations

• Strengthen deterrence through higher fines

• Introduce flexibility through settlements and waivers

Key Highlights :

1. Unified Admin Rulebook

• One consolidated regulation for investigations, fines, sanctions, and procedures across all commercial legislation.

• A future-proof platform for updates and amendments.

2. Updated Fine Levels

• New Level 9 fine tier introduced (up to USD 54 million).

• Repeat violations can result in escalated fine levels.

3. Two-Tiered Fairness System

• Tier 1: For minor issues like late filings
  Streamlined process
  30% discount if paid within 14 days

• Tier 2: For serious breaches
  Heavier fines, disqualifications, licence actions
  Full procedural safeguards (warning + decision notices)

4. Waiver Option

• Entities can admit liability and skip Tier 2 procedures.

• Reduces burden on both parties, speeds up enforcement.

5. Emergency Powers for RA CEO

• The RA CEO can immediately suspend/cancel licences in exceptional cases.

• Designed for urgent scenarios where the usual process may delay risk mitigation.

6. Statutory Settlement Agreements

• Formal power to settle Tier 2 enforcement cases at any point.

• Settlement = legally binding and enforceable.

7. Time Limits

• A new statutory time limit on enforcement actions to protect fairness.

What Is RA Asking?

The RA is consulting on:

• Whether discounts and fine tiers are proportionate

• If the waiver system promotes efficiency

• The adequacy and safeguards of the CEO’s emergency powers

• Effectiveness of the settlement process

Next Step? Wait for the Final Rulebook

Do not act yet. The Admin Regulations are still proposals and will only take effect after the ADGM Board approves and publishes them with final guidance.

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