Cyber Strategy
Cyber Secure
Cyber Operations
Cyber Response
Cyber ResilienceAbu Dhabi Global Market (ADGM) is the UAE’s premier international financial centre, operating across Al Maryah Island (and since 2024, Al Reem Island). Established in 2013 and fully operational from 2015, ADGM blends a common-law legal system with a comprehensive regulatory ecosystem tailored for global financial and non‑financial institutions. Firms operating within ADGM must meet both local and UAE federal cybercrime regulations.
At DTS Solution, we help firms build risk-based, enforceable cybercrime prevention programs aligned with the Financial Services Regulatory Authority (FSRA) expectations.
The FSRA and Cybersecurity Oversight
The FSRA is ADGM’s regulatory body responsible for a fair, efficient, and growth-oriented financial marketplace. It governs financial services licensing, anti-money laundering, securities listing, and cybercrime prevention. The FSRA’s Financial Crime and Cybercrime Prevention (FCCP) unit mandates that firms implement cyber risk controls appropriate to their scale, business model, and digital footprint, ensuring responsiveness to evolving risk thresholds.
UAE Federal Cybercrime Laws
In parallel, Federal Decree‑Law No. 34 of 2021 (effective January 2022) sets the framework for penalizing cyber offenses. These include:
- System hacking: Fines from AED 100,000 to AED 300,000, escalating if sensitive data is compromised
- Government system attacks: Possible prison plus penalties up to AED 1.5 million
- Personal data violations: Up to AED 100,000, with heftier fines for financial or health records
- Confidential leaks/impersonation: Years in prison plus multi-million dirham fines
- Fake news or hoaxes: Mandatory prison and steep fines, especially during crises
These provisions operate in tandem with FSRA expectations, making compliance non-negotiable for ADGM-regulated entities.
Recent FSRA Guidance: Notices & Circulars
In 2025, the FCCP issued specific Notices to bolster cyber defense:
- Notice No. 13 of 2025: Mandates prompt reporting of IT and cyber incidents through defined templates.
- Notice No. 33 of 2025: Provides guidance on phishing, emphasizing identification and prevention.
- Notice No. 84 of 2024: Alerts firms to Indicators of Compromise (IoCs) issued by the Cyber Security Council
These circulars shape internal policies, incident response procedures, and overall resilience planning.
Consultation Paper No. 3 of 2025 – Toward a Cyber Risk Framework
ADGM’s proposed Cyber Risk Management Framework seeks to standardize controls across authorised firms and recognised bodies, including tech vendors.
Highlights include:
- A baseline standard of cyber hygiene.
- Enhanced oversight over third-party providers.
- Potential requirement for annual risk management returns.
- Increased thematic and risk-based supervisory reviews
Why Cyber Governance Matters in ADGM
ADGM isn’t an isolated zone but a densely interconnected ecosystem. Weak cybersecurity in one entity can expose others across sectors, increasing systemic risk. FSRA expects industry-wide maturity in cyber governance. Moreover, UAE’s upcoming FATF evaluation in 2026 reinforces the urgency: regulators are benchmarking against global standards, and non-compliance invites legal, financial, and reputational consequences.
What FSRA Requires from Regulated Firms
The FSRA’s Financial Crime and Cybercrime Prevention (FCCP) unit oversees anti-money laundering (AML), targeted financial sanctions (TFS), and cybercrime policy enforcement across all ADGM-licensed firms. Its approach is risk-based: your cyber program must reflect your scale, service offerings, exposure points, and third-party dependencies.
You’re expected to implement clear controls for:
- Detecting and responding to cyber incidents
- Preventing unauthorized access or data theft
- Protecting cryptographic keys and wallet infrastructure
- Auditing all activity tied to sensitive systems
- Managing third-party risk across outsourced services
- Reporting threats, breaches, or attacks promptly
Abu Dhabi Global Market (ADGM) is the UAE’s premier international financial centre, operating across Al Maryah Island (and since 2024, Al Reem Island). Established in 2013 and fully operational from 2015, ADGM blends a common-law legal system with a comprehensive regulatory ecosystem tailored for global financial and non‑financial institutions. Firms operating within ADGM must meet both local and UAE federal cybercrime regulations.
At DTS Solution, we help firms build risk-based, enforceable cybercrime prevention programs aligned with the Financial Services Regulatory Authority (FSRA) expectations.
The FSRA and Cybersecurity Oversight
The FSRA is ADGM’s regulatory body responsible for a fair, efficient, and growth-oriented financial marketplace. It governs financial services licensing, anti-money laundering, securities listing, and cybercrime prevention. The FSRA’s Financial Crime and Cybercrime Prevention (FCCP) unit mandates that firms implement cyber risk controls appropriate to their scale, business model, and digital footprint, ensuring responsiveness to evolving risk thresholds.
UAE Federal Cybercrime Laws
In parallel, Federal Decree‑Law No. 34 of 2021 (effective January 2022) sets the framework for penalizing cyber offenses. These include:
- System hacking: Fines from AED 100,000 to AED 300,000, escalating if sensitive data is compromised
- Government system attacks: Possible prison plus penalties up to AED 1.5 million
- Personal data violations: Up to AED 100,000, with heftier fines for financial or health records
- Confidential leaks/impersonation: Years in prison plus multi-million dirham fines
- Fake news or hoaxes: Mandatory prison and steep fines, especially during crises
These provisions operate in tandem with FSRA expectations, making compliance non-negotiable for ADGM-regulated entities.
Recent FSRA Guidance: Notices & Circulars
In 2025, the FCCP issued specific Notices to bolster cyber defense:
- Notice No. 13 of 2025: Mandates prompt reporting of IT and cyber incidents through defined templates.
- Notice No. 33 of 2025: Provides guidance on phishing, emphasizing identification and prevention.
- Notice No. 84 of 2024: Alerts firms to Indicators of Compromise (IoCs) issued by the Cyber Security Council
These circulars shape internal policies, incident response procedures, and overall resilience planning.
Consultation Paper No. 3 of 2025 – Toward a Cyber Risk Framework
ADGM’s proposed Cyber Risk Management Framework seeks to standardize controls across authorised firms and recognised bodies, including tech vendors.
Highlights include:
- A baseline standard of cyber hygiene.
- Enhanced oversight over third-party providers.
- Potential requirement for annual risk management returns.
- Increased thematic and risk-based supervisory reviews
Why Cyber Governance Matters in ADGM
ADGM isn’t an isolated zone but a densely interconnected ecosystem. Weak cybersecurity in one entity can expose others across sectors, increasing systemic risk. FSRA expects industry-wide maturity in cyber governance. Moreover, UAE’s upcoming FATF evaluation in 2026 reinforces the urgency: regulators are benchmarking against global standards, and non-compliance invites legal, financial, and reputational consequences.
What FSRA Requires from Regulated Firms
The FSRA’s Financial Crime and Cybercrime Prevention (FCCP) unit oversees anti-money laundering (AML), targeted financial sanctions (TFS), and cybercrime policy enforcement across all ADGM-licensed firms. Its approach is risk-based: your cyber program must reflect your scale, service offerings, exposure points, and third-party dependencies.
You’re expected to implement clear controls for:
- Detecting and responding to cyber incidents
- Preventing unauthorized access or data theft
- Protecting cryptographic keys and wallet infrastructure
- Auditing all activity tied to sensitive systems
- Managing third-party risk across outsourced services
- Reporting threats, breaches, or attacks promptly
How DTS Solution helps organizations operating in the ADGM
DTS Solution is a leading cybersecurity advisory and consulting firm, trusted by over 350 clients across the Middle East and beyond.
With deep expertise in enterprise security, risk management, compliance, and cyber resilience, DTS has delivered measurable impact through 80+ VAPT engagements, 250+ firewall migrations, and over 20 successful NESA compliance implementations.
Backed by a team of certified experts and industry accreditations including ISO 27001, CREST, and DESC Cyber Force Program recognition, DTS continues to set the benchmark for excellence in cybersecurity, earning multiple awards for its innovative and client-centric approach.
We deliver a full suite of cybersecurity services tailored to meet the FSRA’s Spot Virtual Asset Framework under ADGM regulations. Our coverage aligns with technology governance, safe custody, wallet security, and financial crime compliance.
1. Risk-Based Assessment & Program Design
Tailored frameworks calibrated to your firm’s size, operations, threat exposure, and technology stack.
2. Incident Response & Reporting Preparedness
Build and test response playbooks using FSRA templates. Ensure reporting agility and regulatory readiness.
3. Technical Controls Implementation
Deploy phishing safeguards, endpoint protection, data encryption, access management, network segmentation, patching, and logging.
4. Third-Party Risk Governance
Evaluate vendors, secure meaningful contractual commitments, and maintain clarity on outsourced data access and security obligations.
5. Regulatory Advisory & Cyber Training
Educate staff on FSRA and federal cyber obligations, including mandatory reporting and internal governance responsibilities.
6. Pre-Audit Review & Assurance
Simulate FSRA audits, run mock reviews, and fill compliance gaps proactively—before regulators raise concerns.
Final Thoughts
As ADGM matures into one of the region’s largest financial ecosystems, cyber resilience becomes a core operational imperative. ADGM’s adoption of English common law, robust licensing framework, and jurisdiction expansion onto Al Reem Island underline its ambition.
Want strategic clarity on ADGM cybersecurity compliance? DTS is ready to help you build it.
How DTS Solution helps organizations operating in the ADGM
DTS Solution is a leading cybersecurity advisory and consulting firm, trusted by over 350 clients across the Middle East and beyond.
With deep expertise in enterprise security, risk management, compliance, and cyber resilience, DTS has delivered measurable impact through 80+ VAPT engagements, 250+ firewall migrations, and over 20 successful NESA compliance implementations.
Backed by a team of certified experts and industry accreditations including ISO 27001, CREST, and DESC Cyber Force Program recognition, DTS continues to set the benchmark for excellence in cybersecurity, earning multiple awards for its innovative and client-centric approach.
We deliver a full suite of cybersecurity services tailored to meet the FSRA’s Spot Virtual Asset Framework under ADGM regulations. Our coverage aligns with technology governance, safe custody, wallet security, and financial crime compliance.
1. Risk-Based Assessment & Program Design
Tailored frameworks calibrated to your firm’s size, operations, threat exposure, and technology stack.
2. Incident Response & Reporting Preparedness
Build and test response playbooks using FSRA templates. Ensure reporting agility and regulatory readiness.
3. Technical Controls Implementation
Deploy phishing safeguards, endpoint protection, data encryption, access management, network segmentation, patching, and logging.
4. Third-Party Risk Governance
Evaluate vendors, secure meaningful contractual commitments, and maintain clarity on outsourced data access and security obligations.
5. Regulatory Advisory & Cyber Training
Educate staff on FSRA and federal cyber obligations, including mandatory reporting and internal governance responsibilities.
6. Pre-Audit Review & Assurance
Simulate FSRA audits, run mock reviews, and fill compliance gaps proactively—before regulators raise concerns.
Final Thoughts
As ADGM matures into one of the region’s largest financial ecosystems, cyber resilience becomes a core operational imperative. ADGM’s adoption of English common law, robust licensing framework, and jurisdiction expansion onto Al Reem Island underline its ambition.
Want strategic clarity on ADGM cybersecurity compliance? DTS is ready to help you build it.
Dubai