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2023

ADGM Category 3C License: Managing Collective Investment Funds and Assets

Category 3C License can also provide Financial Services under Category 4 but are restricted from offering services in Categories 1, 2, 3A, or 3B.

Overview of ADGM Category 3C License

The ADGM Category 3C License permits an Authorised Firm to offer one or more of the following financial services:

  • Managing a Collective Investment Fund.

  • Managing Assets.

  • Providing Trust Services as a trustee of an express trust.

  • Providing Custody services (other than for a fund).

  • Managing a Profit Sharing Investment Account (received on a restricted basis).

Firms holding a Category 3C License can also provide Financial Services under Category 4 but are restricted from offering services in Categories 1, 2, 3A, or 3B.

Capital Requirements:

  • Base Capital: USD 500,000.

  • Fund Manager Specific Requirements:

    • Public Fund: USD 140,000.

    • Exempt Funds/QIFs: USD 70,000.

  • Expenditure-Based Capital Requirement: 18/52 of annual operating expenditure (since the Fund Manager will handle or control client money).

  • Capital Plan: Must be detailed in the Internal Capital Adequacy Assessment Process (ICAAP) Report.

  • Additional Requirements: The FSRA may impose further capital requirements based on the application review.

Licensing Process for ADGM Category 3C

To obtain an ADGM Category 3C License, an applicant must submit a detailed application to the Financial Services Regulatory Authority (FSRA), which will assess the merits and suitability of the applicant and the requested license category.

The Application Process

  1. Initial Review: The FSRA will conduct an informal review of the draft Regulatory Business Plan and projected financials. If the FSRA is satisfied, the applicant will be invited to submit a full formal application, including a finalized Regulatory Business Plan.

  2. MVG Dubai Office Support

    Introduction to the Regulator: MVG Dubai facilitates introductions to the FSRA to streamline the regulatory process.

    Drafting Regulatory Business Plan: We prepare a comprehensive Regulatory Business Plan (RBP) that includes application forms, business flow processes, and organizational charts.

    Financial Modeling and ICAAP: Our team creates a detailed three-year financial model and drafts the ICAAP and Internal Risk Assessment Process (IRAP) reports, essential for evaluating capital adequacy.

    Policy and Manual Preparation: MVG Dubai assists in preparing necessary policies and manuals, including Compliance, Anti-Money Laundering (AML), Risk Management, Remuneration, Governance, Conflicts of Interest, and Business Continuity Planning.

    Form Preparation and Submission:

    Regulatory Application Drafting: MVG Dubai drafts the regulatory application for both the firm and its key individuals, ensuring compliance with FSRA requirements.

    Submission and Appointment Support:

    Additional Support:

    • Office Lease Assistance: Help with locating and leasing suitable office space.

    • Bank Introduction: Facilitation of introductions to UAE banks for account opening and banking services.

    • License Issuance: Support in obtaining the financial services license from the FSRA.

    • Regulatory Application Submission: We manage the submission of the Regulatory Application, including policies and the appointment of key roles such as Senior Executive Officer (SEO), Finance Officer (FO), Risk Officer (RO), Money Laundering Reporting Officer (MLRO), and Compliance Officer (CO).

    • AUT – CORE: Completion of this form, covering details about the applicant, its activities, prospective clients, and controllers.

    • AUT – IND: For individuals in mandatory functions, including directors, senior executive officers, finance officers, compliance officers, and money laundering reporting officers.

    • AUT – AMS: For firms applying to conduct financial services related to credit arrangement or investment deals, as part of ADGM CO’s proposed activities.

Post-Application Process

The FSRA will review the application and engage in ongoing dialogue with the applicant, which may include interviews with the nominated authorized individuals. Upon satisfactory review, the FSRA will issue an In-Principle approval, which will include conditions to be met before the final license is granted. These conditions typically involve:

  • Incorporation or registration of the entity with the ADGM Registrar of Companies.

  • Opening a local bank account and providing proof of capital remittance to the FSRA.

  • Providing evidence of office space for conducting financial activities.

Once these conditions are fulfilled, the FSRA will issue the formal license.

Conclusion

Securing an ADGM Category 3C License involves a rigorous application process and adherence to regulatory standards. MVG Dubai offers expert support throughout the licensing process, ensuring compliance with FSRA requirements and facilitating a smooth entry into the ADGM financial environment. Our comprehensive services help firms navigate the regulatory landscape and establish a successful presence in the UAE.


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