Guidance on Prohibition on Accepting or Distributing Cash by Certain Licence Holders

Confidential
REGISTRATION AUTHORITY - GUIDANCE
Guidance on Prohibition on Accepting or
Distributing Cash by Certain Licence
Holders
August 2026

CONTENTS

1. INTRODUCTION ....................................................................................................3
   Introduction to ADGM......................................................................................................... 3
   Guidance overview and application .................................................................................... 3

2. BACKGROUND......................................................................................................4

3. SCOPE OF THE PROHIBITION ................................................................................4

4. PERMITTED PAYMENT METHODS...........................................................................4

5. THRESHOLD EXCEPTION.......................................................................................5

6. ACCIDENTAL RECEIPT OF CASH............................................................................5

7. EXEMPTIONS.........................................................................................................6

8. COMPLIANCE EXPECTATIONS...............................................................................6

9. SUPERVISORY APPROACH ....................................................................................7
   DISCLAIMER ................................................................................................................8

10. INTRODUCTION
    Introduction to ADGM
    ADGM is an international financial centre established pursuant to Abu Dhabi Law No. 4 of 2013 in the Emirate of Abu Dhabi, United Arab Emirates. With its own civil and commercial laws based on English common law, ADGM offers the local, regional and international business communities a world-class legal system and regulatory regime. The Registration Authority (“RA”) of ADGM is the Registrar of companies within ADGM as well as the commercial and audit regulator of ADGM. The RA is responsible for the licensing, registration and incorporation of entities seeking to establish a presence in ADGM, as well as the monitoring and enforcing of ADGM’s commercial legislation and facilitating government related services. Guidance overview and application This guidance is issued under section 23(1) of the Commercial Licensing Regulations 2025 (“CLR 2025”) to elaborate on the prohibition on accepting or distributing cash as set out under Rule 16 of the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules 2026(A) (the “CLR Rules”). This guidance sets out the RA’s position on the application and scope of the prohibition on accepting or distributing physical cash by licence holders carrying on specified licensed activities, including real estate agency services involving the acquisition or disposal of real property, accountancy services, audit services, insolvency practitioner services, tax services, legal services, and company services. Note: the RA’s prohibition on accepting or distributing cash, applies only to firms licensed to carry on the activities specified above, i.e. real estate agency, accountancy, audit, insolvency practitioner, tax, legal and company services. This guidance has been prepared to provide information and clarification on the cash acceptance and distribution prohibition to applicable firms. This guidance should be read in conjunction with ADGM’s commercial legislation and where applicable, Financial Services Regulatory Authority’s (“FSRA”) Anti-Money Laundering and Sanctions Rules and Guidance (AML Rules) which are available from www.adgm.com.

11. BACKGROUND
    The RA has introduced a prohibition on the acceptance and distribution of physical cash by certain licence holders carrying on specified professional activities. The prohibition forms part of ADGM’s continued efforts to strengthen transparency, mitigate financial crime risks, and support the integrity of ADGM’s regulatory framework. Cash transactions may present increased risks due to reduced traceability and challenges associated with verifying the source and movement of funds. The prohibition is intended to reduce these risks by requiring payments connected with certain professional services to be made through traceable payment channels.

12. SCOPE OF THE CASH PROHIBITION
    The prohibition applies only to licence holders carrying on any of the following licensed activities:

• real estate agency services involving the acquisition or disposal of real property;
• accountancy services;
• audit services;
• insolvency practitioner services;
• tax services;
• legal services; or
• company services.
  A licence holder carrying on any of the above activities must not accept or distribute physical cash (including banknotes and coins) in connection with those activities. The prohibition applies whether or not a firm’s licence includes other activities. For example, a firm licensed to conduct both tax services and management consultancy services will be subject to the prohibition. However, for this firm, the prohibition will apply only in relation to the provision of tax services.

4. PERMITTED PAYMENT METHODS
   The prohibition does not prevent licence holders from receiving fees or payments for their services, provided that they do not accept or distribute cash payments in contravention of the prohibition.

Payments may continue to be made through traceable financial channels, including:

• bank transfer;
• cheque;
• regulated payment instruments; or
• another traceable financial channel acceptable to the Registrar.

5. THRESHOLD EXCEPTION
   The prohibition does not apply where the total amount of cash received or distributed in connection with a transaction does not exceed USD 3,000 (or the equivalent amount in another currency). The threshold applies to the total amount of cash received or distributed in connection with a transaction and not to individual cash payments forming part of that transaction. Licence holders must not accept, distribute or process cash transactions that are structured in a manner intended to circumvent the application of the prohibition. Licence holders should consider the total cash amount received or distributed in connection with a transaction when determining whether the USD 3,000 threshold applies.
6. ACCIDENTAL RECEIPT OF CASH
   Where a licence holder inadvertently receives cash in contravention of the prohibition, the licence holder will not be regarded as having contravened the prohibition if it:

• does not use, deposit, transfer, or otherwise deal with the cash other than for the
  purpose of returning it; and
• returns the cash to the person from whom it was received as soon as reasonably
  practicable.
  Licence holders should retain appropriate records of any such incident and the steps taken to return the cash. Such records should include, at a minimum, the date and amount of cash received, the person from whom it was received, the date on which it was returned, the amount returned, and the circumstances and rationale for returning the amount.

7. EXEMPTIONS
   In exceptional circumstances, a licence holder may apply to the Registrar for an exemption from the prohibition by submitting a written application outlining:

• the exceptional circumstances giving rise to the request;
• the reasons why compliance with the prohibition is not reasonably practicable in
  the particular circumstances;
• the duration of the exemption sought; and
• the controls that will be implemented to mitigate any financial crime risks.
  The application should include sufficient supporting information and documentation to enable the Registrar to assess the circumstances giving rise to the request, the reasons why compliance is not reasonably practicable, and the proposed controls. The Registrar may request further information or documentation as it considers necessary. Any exemption granted by the Registrar may be subject to such conditions as the Registrar considers appropriate. The submission of an application for an exemption does not, in itself, suspend or otherwise disapply the prohibition. The prohibition continues to apply unless and until an exemption is granted by the Registrar.

8. COMPLIANCE EXPECTATIONS
   Licence holders within scope should review and update their internal policies, procedures, and payment arrangements to ensure compliance with the prohibition. This may include:

• updating client engagement terms and payment instructions;
• ensuring employees understand the prohibition and permitted payment
  methods;
• implementing controls to prevent the acceptance or distribution of prohibited
  cash payments; and
• retaining appropriate records demonstrating compliance.
  The prohibition complements existing obligations applicable to licence holders, including applicable anti-money laundering and regulatory requirements.

9. SUPERVISORY APPROACH
   The RA will monitor compliance with the prohibition as part of its supervisory and regulatory functions. Licence holders within scope should ensure that they have appropriate policies, procedures, and controls in place to identify and prevent the acceptance or distribution of cash in connection with prohibited activities. The RA may consider a licence holder’s arrangements for compliance with the prohibition as part of its assessment of the licence holder’s compliance with applicable regulatory requirements. Where the RA identifies potential non-compliance, it may engage with the relevant licence holder to understand the circumstances, including the nature of the transaction, the steps taken by the licence holder, and any remedial action implemented. A licence holder that contravenes the prohibition may be subject to enforcement action by the RA in accordance with Part 8 of the Administrative Regulations 2025, which may include the imposition of financial penalties or other applicable regulatory measures. The RA will take into account the circumstances of any non-compliance, including whether the breach was isolated or recurring, the controls maintained by the licence holder, whether the licence holder took prompt remedial action, and any other relevant factors.

DISCLAIMER
This guidance is a non-binding indicative guidance and should be read together with the relevant legislation, in particular ADGM’s Commercial Licensing Regulations 2025, the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules 2026(A) and any other relevant regulations and enabling rules, which may change over time without notice. Information in this guidance is not to be deemed, considered, or relied upon as legal advice and should not be treated as a substitute for specific advice concerning any individual situation. Any action taken upon the informationprovidedin this guidance is strictly at yourownrisk and the RA will not be liable for any losses and damages in connection with the use of or reliance oninformation providedinthis guidance. The RAmakes no representations as to the accuracy, completeness, correctness, or suitability of any information provided in this guidance.