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ADGM: 2026 Update to Legal Persons and Arrangements (LPA) Risk Assessment

The Abu Dhabi Global Market (ADGM) has published its 2026 update to the Money Laundering and Terrorist Financing (ML/TF) Risk Assessment of Legal Persons and Arrangements (LPA), reflecting significant growth in scale and complexity and aligning with the UAE National Risk Assessment.

The updated assessment provides a jurisdiction‑specific view of ML/TF risks across ADGM’s legal structures and forms a key part of its risk‑based regulatory and supervisory framework. Since the 2024 assessment, the LPA population has grown from 7,173 to 12,302, a 72% increase, necessitating a more granular reassessment of vulnerabilities, mitigants, and supervisory priorities.

The 2026 update incorporates developments from the UAE National Risk Assessment (NRA) and confirms that ADGM’s overall ML/TF risk profile remains broadly stable. While threats have evolved, strengthened mitigants — including enhanced beneficial ownership transparency, increased inspection activity, and expanded enforcement tools — have offset risk exposure.

According to ADGM Chairman Ahmed Jasim Al Zaabi, the update reflects a rigorous, evidence‑based approach to safeguarding integrity and transparency, supporting trust, growth, and competitiveness. The assessment is embedded in ADGM’s daily regulatory work and serves as a reference for financial institutions, company service providers, virtual asset service providers, and designated non‑financial businesses to calibrate due diligence and identify higher‑risk structures.

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