ADGM introduces new fine and enforcement framework: Abu Dhabi Global Market’s (ADGM) Registration Authority (RA) has published new administrative regulations 2025 (pdf), alongside amendments to related commercial legislation, introducing new tier-based fines for contraventions, and expanding its supervisory powers, according to a press release (pdf). The new regulations took effect immediately upon publication.

A unified regime for all contraventions: All RA enforcement, investigation, and sanctioning powers are consolidated under one framework governing every entity subject to ADGM’s commercial laws. The reforms establish two main contravention categories — Tier 1 and Tier 2 — each with its own process and penalty ceiling. For both tiers, fined parties have 30 days to seek reduction or revocation.

  • Tier 1 contraventions cover minor breaches, with fines capped at USD 2k, which must be paid within 30 days of receiving notice. Firms can file statements of representatives within 30 days to seek reduction or revocation;
  • Tier 2 contraventions include more serious offenses and carry fines of up to USD 54 mn, along with other enforcement actions such as license suspension for up to 12 months, cancellation, disqualification, prohibition orders, imposition of certain requirements, changes to the type of license issued, and striking contravening parties off the register. The RA will first issue a written warning notice, setting a deadline for the party to submit any material to challenge the issuance. The authority can then issue a decision notice upholding the fine or a discontinuance notice annulling it. The two parties can also enter into a settlement.

Repeat contraventions: ADGM can impose higher fines through a decision notice if another Tier 2 contravention is committed within 12 months of the first.

Expanded investigative and supervisory tools: The RA also now has explicit authority to compile information from any connected person, verify submission, and appoint investigators to conduct targeted reviews. It can now also issue supervisory notices without going through the full enforcement process, allowing for immediate license variation or new compliance requirements when risks are identified.

A new rule gives the RA’s CEO statutory exceptional powers to suspend or cancel licenses, or issue prohibition orders immediately — bypassing Tier 2 procedures when there is serious contravention, criminal suspicion, or imminent material harm to consumers, market confidence, or public safety. The CEO must issue an exceptional notice setting out grounds, actions taken, and the right to judicial review before the ADGM courts.

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