ADGM updates legal-persons ML/TF risk assessment
ADGM firms must calibrate CDD and monitoring to the 2026 LPA ML/TF risk assessment
Change
ADGM published its 2026 Legal Persons and Arrangements ML/TF risk assessment after a 72% increase in LPA population since 2024.
Why it matters
The assessment updates ADGM's supervisory view of ML/TF risk across legal persons and arrangements. Financial institutions, company service providers, VASPs and DNFBPs must use the revised risk view to calibrate customer due diligence, structure-risk assessment, ongoing monitoring and escalation for higher-risk legal structures.
Implications
- — ADGM financial institutions must map customer due diligence and ongoing-monitoring controls for legal persons and arrangements to the 2026 LPA risk assessment.
- — Company service providers and formation teams must account for the updated LPA risk indicators when supporting incorporation and commercial licensing applications.
- — VASPs and DNFBPs operating in ADGM must calibrate customer-risk assessment and escalation for higher-risk structures and behaviours identified in the LPA risk assessment.
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