ADGM · FSRA AML Rulebook VER11.210526 · For the MLRO
Know where you stand, before the regulator asks.
A recurring self-assessment against every Rulebook chapter that applies to your firm. Each requirement gets a verdict, a maturity score and the evidence behind it. The reports the regulator requires are drafted from your answers.
Content pinned to VER11.210526. Re-tested on each ADGM update.
In partnership with
At a glance
- Rulebook chapters covered
- 16
- Assessable requirements
- 75
- Mandatory reports a year
- 3
- Assessments
- Unlimited
- Seats included
- 1 MLRO + 2 business liaisons
The reporting year
Three artifacts are mandatory. Everything else is rhythm.
Some vendors sell seven regulatory reports a year. The Rulebook does not ask for that. Two MLRO reports, one Annual AML Return and the effectiveness review that feeds them. Board packs are good governance, not a filing.
What feeds what. The effectiveness review supplies item (a) of each MLRO report. The MLRO reports and the gap register feed the Annual AML Return working paper. Senior management's assessment of each report is itself a record (Rules 12.4.2 to 12.4.3).
Who it assesses
Your entity type decides which chapters apply.
Stage 1 of every assessment is scoping. Generic GRC tools skip this step.
Authorised Person / Recognised Body
The widest scope. Chapters 1 to 14, with correspondent banking and travel-rule questions when you declare the exposure.
DNFBP
Adds Chapter 15 registration. The correspondent banking chapter falls away. Category captured per Rule 3.2.1.
Representative Office
No customers, so Chapters 7 to 10 do not apply. The shortest assessment.
Non-Profit Organisation
Assessed against Chapter 16 only: control, purpose and six-year fund traceability.
What it asks
The 16-chapter Rulebook, domain by domain.
Every question carries its rule citation, a compliant, partially compliant or non-compliant rubric, and the evidence it expects. Where the ADGM Registration Authority published one, the peer benchmark is there too. 75 assessable requirements in all.
01
Governance, responsibility & compliance culture
Ch. 1 · 4.1
02
Group policies & record-keeping
§ 4.3 · 4.5
03
Annual AML Return readiness & high-risk jurisdictions
§ 4.6 · 4.9
04
Risk-based approach
Ch. 5
05
Business risk assessment
Ch. 6
06
Customer risk assessment
Ch. 7
07
CDD, EDD, SDD, ongoing monitoring & PEPs
Ch. 8
08
Third-party reliance & outsourcing
Ch. 9
09
Correspondent banking, transfers & prohibited accounts
Ch. 10
10
Targeted financial sanctions
Ch. 11
11
MLRO appointment, standing & reporting
Ch. 12
12
AML/ CFT/ CPF training & awareness
Ch. 13
13
SAR/STR governance
Ch. 14
14
DNFBP registration & supervision
Ch. 15
15
Non-profit organisation obligations
Ch. 16
16
Annual effectiveness review
Rule 4.1.1(4)
How it works
Everything sign-in unlocks, in three phases.
Scope and assess
Stage 1 scoping switches domains on and off by entity type and exposure (Rule 1.2.1).
Unlimited versioned assessments, with answers carried forward for delta review.
Verdict, 1 to 5 maturity rating and rationale for each requirement, every question cited.
Track and remediate
Evidence locker with sha-256 fingerprints and six-year retention clocks (Rule 4.5.1).
Every upload filed against the requirement it supports, retrievable within a business day (Rule 4.5.2).
Gap register with severity, owner and due date. Conflicting self-ratings flagged for confirmation.
Report and attest
MLRO semi-annual report, auto-drafted to Rule 12.4.1(a) to (f).
Annual AML Return and effectiveness review working papers.
Quarterly board MI pack. Everything exports to Word with sign-off trails.
Your AML expert
An MLRO seat, filled by AML veterans.
Every assessment needs a GRC liaison. If you do not have one in-house, the RegXpert for this workflow comes from ThinkBOX Consultants, our ADGM partner and a strategic risk management firm for financial institutions.
Their team has spent careers inside banks and regulated firms. They review your answers, challenge the weak ones and guide your team through each assessment.
Practitioners from Standard Chartered, HSBC, Citibank, ICICI and GE Money
Advisory across DIFC and ADGM, including AML manuals and financial crime policy reviews
Outsourced MLRO and Compliance Officer cover for firms without one in-house
Hands-on experience of regulatory scrutiny, breach remediation and fraud investigations
Optional. Bring your own MLRO and you pay the platform fee only. Consultancy is sold in 10-hour blocks, priced by your licence category.
Demo video
See an assessment end to end.
A short walkthrough of the workspace.
Scoping a DNFBP in under two minutes
Answering a requirement with evidence attached
The MLRO review and return-for-more-detail step
An MLRO report drafted from the assessment
Pricing
Priced by entity type.
Annual subscription per organisation, in USD. Each tier includes 1 MLRO seat and 2 business liaison seats, unlimited assessment cycles and all reports. 30-day free trial from your first assessment.
Tier · by entity type
Pricing
Additional ThinkBOX MLRO consultancy
AML Essentials
DNFBPs, NPOs (Non-Profit Organisations)
US$1,290 / year
US$1,000 / 10 hours
AML Standard
Representative Offices, Authorised Person (Small)
US$2,790 / year
US$1,500 / 10 hours
AML Advanced
Authorised Person (Large), Credit Rating Agency & Recognised Body
US$4,690 / year
US$2,000 / 10 hours
MLRO Compliance Consultancy
AML Essentials entities (above), licensed per client entity
US$1,290 / entity / year
—
Yearly subscription only. MLRO consultancy is optional and delivered by ThinkBOX Consultants. Each block covers 10 hours over the year, and you can buy as many blocks as you need. Pricing depends on the nature of the work.
An Authorised Person is Small in FSRA Category 3C or 4, and Large in Category 1, 2, 3A, 3B or 5. An MLRO consultancy pays each client entity's own tier.
Book a demo
Want to see it on your own firm's scope?
We will walk through the chapters that apply to your entity type and show you the reports they produce.
Boundaries and official sources
What it does, and what it leaves to you.
What this workflow does not do
No live CDD, screening or transaction monitoring. No SAR or STR filing to goAML. No direct FSRA Connect submission. RegXperience assesses and reports on your AML programme. It does not run it.
The FSRA does not publish the Return's field-by-field form, so our working paper is a reasoned Rulebook mapping, and it says so on the page.
Official sources
ADGM AML and Sanctions Rules and Guidance, VER11.210526. The primary text. It supersedes every summary in this product.
ADGM Financial & Cyber Crime Prevention hub · FSRA Connect for Return filing · UAE FIU goAML for SAR and STR filing.
Not legal advice. The AML Rulebook and Federal AML legislation prevail.
Content pinned to this version. Re-validated on each ADGM update.