What is the money laundering risk rating for money or value transfer services in ADGM?
Money or value transfer services in ADGM carry a medium-high residual ML risk rating, the highest of any ADGM financial sector. Although the number of licensed MVTS firms is relatively low, this is the largest ADGM sector by customer base because these firms are authorised to deal with individual customers.
Control effectiveness for the MVTS sector is deemed partially effective, mainly because of deficiencies and breaches of AML requirements identified by ADGM. Several risk factors combine: a diverse customer base, extensive geographical exposure, a wide array of service offerings, a history of previous supervision and regulatory action, the rapid pace of transactions, remote and non-face-to-face onboarding, and increasing reliance on advanced technology.
The combination of retail customer access and cross-border transfer capability is what separates MVTS from the rest of ADGM, where wholesale and institutional relationships dominate.
Legal Reference (source document):
· UAE Money Laundering and Terrorist Financing National Risk Assessment, 2nd NRA (2024)
· National Anti-Money Laundering and Combatting Financing of Terrorism and Financing of Illegal Organizations Committee
Scope note: ADGM MVTS ratings are separate from mainland exchange house and hawala provider ratings.
Further reading: AML compliance for ADGM licensed firms
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