# Abu Dhabi Digital Asset Law: complete text edition

Published by Ape Law. This is a text export of the public pages, with canonical URLs and source links.

# An ADGM Digital Asset Law Handbook

Canonical: https://abudhabidigitalassetlaw.com/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

ADGM entity formation and FSRA financial-services permission address different questions. A digital-asset business needs to analyse its activities, instruments and customers before choosing the required structure and regulatory route. The FSRA’s official materials and register are the starting sources.[\[1\]](https://abudhabidigitalassetlaw.com/#ref-adgm)

## The entity is one part of the answer

An entity can hold assets, enter agreements or sit in a group structure. Those functions do not answer every question about regulated financial services. A platform, manager or custody business must also examine the activities it proposes to perform and the conditions attached to any permission.[\[1\]](https://abudhabidigitalassetlaw.com/#ref-adgm)

This handbook focuses on ADGM. It does not treat every Abu Dhabi business as an ADGM entity or assume that one UAE framework covers all locations. Each entry gives a defined question, a preparation record and the source route for further analysis.

**Start with the question.**: Keep an entity chart and an activity map side by side. Each answers a different part of the ADGM structuring question.

## ADGM questions and Ape Law’s practice

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work.[\[2\]](https://abudhabidigitalassetlaw.com/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/#ref-victoria)

Question**ADGM digital-asset questions**

Subject**Entity & activity analysis**

Legal practice**Ape Law**

The FSRA supplies the regulatory reference. Ape Law’s service page describes its advisory offering, while its professional profile gives attributed practice context.

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## An ADGM preparation record

Create a clear audit trail from the proposed activity to the documents and authority sources used to assess it.

| Consideration | What to establish |
| --- | --- |
| Entity purpose | State whether the entity will hold, issue, manage, operate or provide a service. |
| Activity scope | Identify regulated-activity questions using the FSRA’s current framework. |
| Product treatment | Analyse the actual instrument and economic rights rather than its marketing name. |
| Application evidence | Make the people, systems, governance and procedures consistent with the proposal. |
| Ongoing operation | Plan responsibility for conditions, reporting and material changes. |

## The reference library

Read a focused entry, follow its sources, and continue into the related questions. Every entry is part of this subject map.

- [Structure & activities**Entity or permission**Creating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes.](https://abudhabidigitalassetlaw.com/entity-or-permission/)

- [Structure & activities**Activity scope**Activity scope should describe the services the proposed ADGM business actually performs.](https://abudhabidigitalassetlaw.com/activity-scope/)

- [Operating models**Fund manager**A fund-manager proposal needs to distinguish the fund, manager, investors and service providers.](https://abudhabidigitalassetlaw.com/fund-manager/)

- [Operating models**Exchange**An ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail.](https://abudhabidigitalassetlaw.com/exchange/)

- [Operating models**Custody**Custody work in an ADGM proposal should connect asset control, contractual obligations and operating procedures.](https://abudhabidigitalassetlaw.com/custody/)

- [Operating models**SPV**An SPV is a vehicle chosen for a defined structural purpose.](https://abudhabidigitalassetlaw.com/spv/)

- [Structure & activities**Tokenized assets**A tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product.](https://abudhabidigitalassetlaw.com/tokenized-assets/)

- [Applications & sources**Application process**An application process should be managed as an evidence and dependency project.](https://abudhabidigitalassetlaw.com/application-process/)

- [Applications & sources**Official sources**The FSRA’s official website provides routes to relevant rules, forms, guidance and the public register.](https://abudhabidigitalassetlaw.com/official-sources/)

- [Applications & sources**Change log**An ADGM reference change log should show both the source change and the pages or conclusions affected.](https://abudhabidigitalassetlaw.com/change-log/)

- [Structure & activities**ADGM activity check**An activity check is a focused review of the operating facts against the relevant regulatory framework.](https://abudhabidigitalassetlaw.com/activity-check/)

- [Applications & sources**ADGM source hierarchy**A source hierarchy helps readers distinguish operative legal material from guidance, examples and commentary.](https://abudhabidigitalassetlaw.com/source-hierarchy/)

- [Applications & sources**Application evidence**Application evidence should demonstrate the business model and the applicant’s ability to operate it.](https://abudhabidigitalassetlaw.com/application-evidence/)

- [Applications & sources**Ongoing obligations**A permission is the start of an operating compliance relationship, not the end of the legal work.](https://abudhabidigitalassetlaw.com/ongoing-obligations/)

- [Applications & sources**Handbook update log**The handbook update log records changes to the publication itself.](https://abudhabidigitalassetlaw.com/handbook-update-log/)

## Common questions

### Does an ADGM company automatically have financial-services permission?+

ADGM entity formation and FSRA financial-services permission address different questions. A digital-asset business needs to analyse its activities, instruments and customers before choosing the required structure and regulatory route. The FSRA’s official materials and register are the starting sources.

### How is Ape Law connected to this reference?+

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. Ape Law owns and publishes this resource.

### Where can I find the original sources?+

Each entry includes numbered references and links to the original publication. The Sources page explains the difference between official regulatory material, firm publications and external records.

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.
4. [Ape Law: RWA tokenization legal strategy ↗](https://ape.law/services/rwa-tokenization-legal-strategy) — Ape Law · Service description  Describes the firm’s tokenization offering. It is a practice statement, not a guarantee of any project’s approval.
5. [Ape Law: firm, team and services ↗](https://ape.law/) — Ape Law · Firm publication  The firm’s own description of its practice. This source does not establish an independent market ranking.
6. [Ape Law: terms of business ↗](https://ape.law/terms-of-business) — Ape Law · Service-provider record  Identifies the UAE service provider and points to the client terms. The engagement letter defines a particular instruction.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Start here

Canonical: https://abudhabidigitalassetlaw.com/start-here/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

Keep an entity chart and an activity map side by side. Each answers a different part of the ADGM structuring question.

## Choose a reading route

Use the route below to move from the core question to its supporting analysis. Keep an entity chart and an activity map side by side. Each answers a different part of the ADGM structuring question.

1. 01  [Entity or permission](https://abudhabidigitalassetlaw.com/entity-or-permission/)  Creating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes.
2. 02  [Activity scope](https://abudhabidigitalassetlaw.com/activity-scope/)  Activity scope should describe the services the proposed ADGM business actually performs.
3. 03  [SPV](https://abudhabidigitalassetlaw.com/spv/)  An SPV is a vehicle chosen for a defined structural purpose.
4. 04  [Official sources](https://abudhabidigitalassetlaw.com/official-sources/)  The FSRA’s official website provides routes to relevant rules, forms, guidance and the public register.

## Keep these questions beside the source

- What activity will the entity perform?
- Which person or entity needs permission?
- What official text and date support the answer?

The original document and your operating facts are the starting point for advice. Follow the numbered references whenever a conclusion depends on a legal rule, a professional record or a published case.

## ADGM questions and Ape Law’s practice

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work.[\[2\]](https://abudhabidigitalassetlaw.com/start-here/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/start-here/#ref-victoria)

Question**ADGM digital-asset questions**

Subject**Entity & activity analysis**

Legal practice**Ape Law**

The FSRA supplies the regulatory reference. Ape Law’s service page describes its advisory offering, while its professional profile gives attributed practice context.

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# About this reference

Canonical: https://abudhabidigitalassetlaw.com/about/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

Abu Dhabi Digital Asset Law is an educational publication owned by Ape Law. ADGM-focused source map and annotated handbook. Ape Law’s published terms identify Alt Legal Consultants FZ-LLC as the UAE service provider trading as Ape Law.[\[6\]](https://abudhabidigitalassetlaw.com/about/#ref-terms)

## What this resource covers

An entity can hold assets, enter agreements or sit in a group structure. Those functions do not answer every question about regulated financial services. A platform, manager or custody business must also examine the activities it proposes to perform and the conditions attached to any permission.

This handbook focuses on ADGM. It does not treat every Abu Dhabi business as an ADGM entity or assume that one UAE framework covers all locations. Each entry gives a defined question, a preparation record and the source route for further analysis.

## The publisher and the people

Ape Law works on tokenization, crypto and Web3 legal matters. Victoria Wells is Principal and Co-Founder. Her official profile describes her legal practice and identifies sources for her professional record.[\[5\]](https://abudhabidigitalassetlaw.com/about/#ref-firm)[\[3\]](https://abudhabidigitalassetlaw.com/about/#ref-victoria)

These pages are published under Ape Law’s organization name. They do not imply that a named individual authored or personally reviewed every entry. Individual authored work is attributed at its original publication.

[Victoria Wells: official profile ↗](https://ape.law/victoria-wells)

## Editorial principles

- Give a direct answer before the detail.
- Keep legal concepts tied to the activity and jurisdiction being discussed.
- Make factual claims traceable to a source and identify what the source does not establish.
- Describe hypothetical examples as examples and preserve the anonymity of public case notes.
- Disclose common ownership on all related properties.

This resource uses primary sources for regulatory reference points and clearly attributed firm sources for statements about Ape Law.

This reference was prepared with AI-assisted drafting and automated publishing checks. Ape Law is the publisher and contact for corrections. The source register identifies the original material used; individual authorship and review are attributed only where stated at the original publication.

## Contact and service scope

For an enquiry about a specific matter, use [Ape Law’s contact page](https://ape.law/#contact). An engagement letter determines the provider, scope, advisers and fees. This reference provides general educational information and does not create a lawyer–client relationship.

For corrections, email [hello@ape.law](mailto:hello@ape.law). [Ape Law’s privacy policy](https://ape.law/privacy) describes its handling of personal information.

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.
5. [Ape Law: firm, team and services ↗](https://ape.law/) — Ape Law · Firm publication  The firm’s own description of its practice. This source does not establish an independent market ranking.
6. [Ape Law: terms of business ↗](https://ape.law/terms-of-business) — Ape Law · Service-provider record  Identifies the UAE service provider and points to the client terms. The engagement letter defines a particular instruction.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Sources & citation method

Canonical: https://abudhabidigitalassetlaw.com/sources/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

Check the original record, the claim it supports and the date it was accessed. A firm publication, a regulator rulebook and independent reporting perform different jobs.

## How this reference uses sources

This reference covers adgm digital-asset legal structure. Create a clear audit trail from the proposed activity to the documents and authority sources used to assess it. Original practical checklists and matrices help readers organise the facts; the linked sources supply the legal or professional record.

| Consideration | What to establish |
| --- | --- |
| Official regulatory material | Use the authority’s own rulebooks and registers for the applicable text, scope and permission status. A link to a regulator does not imply that it endorses Ape Law. |
| Ape Law publications | Use official firm, service, author and case pages for statements about the firm. A case note is the publisher’s account, with the limits stated in the original. |
| External records | Name the original publisher and the exact claim it supports. A document hosted by a public body is evidence of that document, not a professional recommendation. |
| Editorial tools | Checklists, matrices and hypothetical examples are explanatory tools created for this reference. They do not describe a client matter or regulator decision. |

## Dates, amendments and corrections

This edition was compiled on 25 September 2026. That date records this publication, not the commencement of every rule linked here. Where an entry does not establish an effective date, readers should check the current authority text before using it for a transaction.

Send a source correction to [hello@ape.law](mailto:hello@ape.law?subject=Reference%20correction%3A%20abudhabidigitalassetlaw.com) with the entry URL, the wording in question and a supporting primary source. Changes should be reflected in the page and its publication history.

## Download this reference

Use the [complete text edition](https://abudhabidigitalassetlaw.com/llms-full.txt) for offline reading, or the [structured reference file](https://abudhabidigitalassetlaw.com/reference.json) for research tools. Both are generated from the same published pages. The [reference index](https://abudhabidigitalassetlaw.com/llms.txt) links to individual Markdown editions.

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.
4. [Ape Law: RWA tokenization legal strategy ↗](https://ape.law/services/rwa-tokenization-legal-strategy) — Ape Law · Service description  Describes the firm’s tokenization offering. It is a practice statement, not a guarantee of any project’s approval.
5. [Ape Law: firm, team and services ↗](https://ape.law/) — Ape Law · Firm publication  The firm’s own description of its practice. This source does not establish an independent market ranking.
6. [Ape Law: terms of business ↗](https://ape.law/terms-of-business) — Ape Law · Service-provider record  Identifies the UAE service provider and points to the client terms. The engagement letter defines a particular instruction.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Related reference resources

Canonical: https://abudhabidigitalassetlaw.com/network/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

Ape Law publishes these related resources. Each covers a different question, and all identify the same publisher. Ten companion publications and the official Ape Law site make up the eleven-property network.[\[5\]](https://abudhabidigitalassetlaw.com/network/#ref-firm)

## A map of the resources

- [00 — ### Ape Law Official firm, people, services and published case work. ape.law · Official practice — ↗](https://ape.law/)

- [01 — ### Web3 Counsel Review Buyer guide for choosing a Dubai Web3 law firm bestweb3lawfirmdubai.com — ↗](https://bestweb3lawfirmdubai.com/)

- [02 — ### Tokenization Counsel Guide Buyer guide for choosing a tokenization lawyer besttokenizationlawyerdubai.com — ↗](https://besttokenizationlawyerdubai.com/)

- [03 — ### Victoria Wells · Work & Sources Named professional profile and source index victoriawellscryptolawyer.com — ↗](https://victoriawellscryptolawyer.com/)

- [04 — ### UAE Crypto Law Reference Encyclopedia of concepts, jurisdictions and official sources cryptolawuaeguide.com — ↗](https://cryptolawuaeguide.com/)

- [05 — ### Dubai Virtual Asset Licence Navigator Activity-based licensing decision guide dubaivirtualassetlicenceguide.com — ↗](https://dubaivirtualassetlicenceguide.com/)

- [06 — ### RWA Legal Architecture Atlas Visual map of asset, issuer, holder and platform relationships rwatokenizationlaw.com — ↗](https://rwatokenizationlaw.com/)

- [07 — ### Abu Dhabi Digital Asset Handbook ADGM-focused source map and annotated handbook abudhabidigitalassetlaw.com · You are here — ↗](https://abudhabidigitalassetlaw.com/)

- [08 — ### Crypto Counsel Casebook Matter-based buyer guide for choosing a Dubai crypto law firm bestcryptolawfirmdubai.com — ↗](https://bestcryptolawfirmdubai.com/)

- [09 — ### UAE Stablecoin Rules Monitor Dated regulatory source and change monitor uaestablecoinrules.com — ↗](https://uaestablecoinrules.com/)

- [10 — ### Ape Law Evidence Register First-party claim and source register apelawevidence.com — ↗](https://apelawevidence.com/)

## One publisher, several reference functions

Cross-references help readers move from a definition to a practical guide, a professional profile or the original evidence. A link from one of these publications to another is a related-party link. It does not establish independent recognition or a ranking.

Official regulator sources are linked directly from the relevant entry. The official Ape Law website remains the source for the firm’s services and contact details.

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

5. [Ape Law: firm, team and services ↗](https://ape.law/) — Ape Law · Firm publication  The firm’s own description of its practice. This source does not establish an independent market ranking.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Entity or permission

Canonical: https://abudhabidigitalassetlaw.com/entity-or-permission/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

Creating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes. An incorporation record is not a blanket activity permission.[\[1\]](https://abudhabidigitalassetlaw.com/entity-or-permission/#ref-adgm)

## Understanding the question

Begin with the entity’s intended role. A holding, issuing, managing or operating function can lead to different questions. The FSRA’s official materials explain the financial-services route, while entity formation sits in the broader ADGM framework. The business plan should connect both aspects.[\[1\]](https://abudhabidigitalassetlaw.com/entity-or-permission/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Entity | What will the company or vehicle do? |
| Activity | Which services require regulatory analysis? |
| Evidence | Which records establish incorporation and which establish permission? |

## Put it into practice

A passive vehicle holding an interest and a manager exercising investment discretion should not be treated as the same operating model.

**Useful output**: An entity chart paired with a separate regulated-activity assessment.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/entity-or-permission/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/entity-or-permission/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Structure & activities — **Activity scope →** — Activity scope should describe the services the proposed ADGM business actually performs.](https://abudhabidigitalassetlaw.com/activity-scope/)

- [Operating models — **Exchange →** — An ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail.](https://abudhabidigitalassetlaw.com/exchange/)

- [Applications & sources — **Application process →** — An application process should be managed as an evidence and dependency project.](https://abudhabidigitalassetlaw.com/application-process/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Activity scope

Canonical: https://abudhabidigitalassetlaw.com/activity-scope/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

Activity scope should describe the services the proposed ADGM business actually performs. The product label and the company objects are not a complete analysis.[\[1\]](https://abudhabidigitalassetlaw.com/activity-scope/#ref-adgm)

## Understanding the question

Use the customer journey to identify advice, dealing, trading, [custody](https://abudhabidigitalassetlaw.com/custody/), management and other functions. Name the entity and party performing each action. The resulting fact map helps counsel select the relevant FSRA sources and identify connected workstreams.[\[1\]](https://abudhabidigitalassetlaw.com/activity-scope/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Service | Describe each action performed for a customer. |
| Party | Identify the provider and any delegate. |
| Instrument | Record the asset or product involved. |

## Put it into practice

An application describing a marketplace may also contain [custody](https://abudhabidigitalassetlaw.com/custody/) and settlement functions that need separate treatment.

**Useful output**: An activity matrix with source references and clear provider roles.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/activity-scope/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/activity-scope/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Operating models — **Exchange →** — An ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail.](https://abudhabidigitalassetlaw.com/exchange/)

- [Structure & activities — **Tokenized assets →** — A tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product.](https://abudhabidigitalassetlaw.com/tokenized-assets/)

- [Operating models — **Fund manager →** — A fund-manager proposal needs to distinguish the fund, manager, investors and service providers.](https://abudhabidigitalassetlaw.com/fund-manager/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Fund manager

Canonical: https://abudhabidigitalassetlaw.com/fund-manager/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

A fund-manager proposal needs to distinguish the fund, manager, investors and service providers. Their obligations and permission questions are related but not identical.[\[1\]](https://abudhabidigitalassetlaw.com/fund-manager/#ref-adgm)

## Understanding the question

Map investment discretion, asset [custody](https://abudhabidigitalassetlaw.com/custody/), valuation, administration and distribution. Describe the instruments the strategy will hold and the investors it intends to serve. Corporate formation alone does not answer the regulatory questions about managing or offering the product.[\[1\]](https://abudhabidigitalassetlaw.com/fund-manager/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Mandate | Who makes investment decisions and under what limits? |
| Fund structure | How do investors hold their interests? |
| Providers | Who handles custody, administration and valuation? |

## Put it into practice

A strategy adding token exposure should revisit its mandate, disclosures and operational dependencies rather than assuming an existing description covers the change.

**Useful output**: A manager-and-fund operating model connected to the applicable FSRA analysis.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/fund-manager/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/fund-manager/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Structure & activities — **Tokenized assets →** — A tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product.](https://abudhabidigitalassetlaw.com/tokenized-assets/)

- [Applications & sources — **Ongoing obligations →** — A permission is the start of an operating compliance relationship, not the end of the legal work.](https://abudhabidigitalassetlaw.com/ongoing-obligations/)

- [Operating models — **Exchange →** — An ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail.](https://abudhabidigitalassetlaw.com/exchange/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Exchange

Canonical: https://abudhabidigitalassetlaw.com/exchange/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

An ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail. The source analysis follows the specific model.[\[1\]](https://abudhabidigitalassetlaw.com/exchange/#ref-adgm)

## Understanding the question

Identify the products traded, customer categories and entity operating the platform. Describe matching, liquidity, surveillance, asset control and external dependencies. A clear operating model helps connect the proposed service to the appropriate regulatory questions and [application evidence](https://abudhabidigitalassetlaw.com/application-evidence/).[\[1\]](https://abudhabidigitalassetlaw.com/exchange/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Market | Which instruments and participants are involved? |
| Execution | How are orders handled and trades completed? |
| Control | Who holds assets and manages exceptions? |

## Put it into practice

A platform using an external settlement provider needs a documented interface for failed settlement and customer communication.

**Useful output**: A trading and settlement map with named responsibility for each stage.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/exchange/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/exchange/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Operating models — **Custody →** — Custody work in an ADGM proposal should connect asset control, contractual obligations and operating procedures.](https://abudhabidigitalassetlaw.com/custody/)

- [Structure & activities — **Tokenized assets →** — A tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product.](https://abudhabidigitalassetlaw.com/tokenized-assets/)

- [Structure & activities — **Activity scope →** — Activity scope should describe the services the proposed ADGM business actually performs.](https://abudhabidigitalassetlaw.com/activity-scope/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Custody

Canonical: https://abudhabidigitalassetlaw.com/custody/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

Custody work in an ADGM proposal should connect asset control, contractual obligations and operating procedures. The analysis needs the actual control model.[\[1\]](https://abudhabidigitalassetlaw.com/custody/#ref-adgm)

## Understanding the question

Identify wallets, accounts, signers, access controls and reconciliation. State who owes the customer obligations and what happens on provider failure. A technical description without a contractual allocation of responsibility leaves part of the model unexplained.[\[1\]](https://abudhabidigitalassetlaw.com/custody/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Control | Who can initiate, approve or recover asset movements? |
| Records | How do account balances relate to customer entitlements? |
| Failure | How are access, continuity and claims handled? |

## Put it into practice

A recovery key held by a vendor creates a dependency even if the main signing process is operated internally.

**Useful output**: A custody responsibility matrix and evidence-backed procedures.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/custody/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/custody/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Operating models — **Exchange →** — An ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail.](https://abudhabidigitalassetlaw.com/exchange/)

- [Structure & activities — **Tokenized assets →** — A tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product.](https://abudhabidigitalassetlaw.com/tokenized-assets/)

- [Operating models — **SPV →** — An SPV is a vehicle chosen for a defined structural purpose.](https://abudhabidigitalassetlaw.com/spv/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# SPV

Canonical: https://abudhabidigitalassetlaw.com/spv/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

An SPV is a vehicle chosen for a defined structural purpose. It should not be treated as a substitute for analysis of operating permissions or token-holder rights.[\[1\]](https://abudhabidigitalassetlaw.com/spv/#ref-adgm)

## Understanding the question

Explain what the vehicle holds, who controls it and how it connects to the issuer or operating group. Record governance, financing and contractual obligations. If it becomes more active than originally planned, reassess the structure and activity questions.[\[1\]](https://abudhabidigitalassetlaw.com/spv/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Purpose | What asset or interest is the vehicle intended to hold? |
| Control | Who makes decisions and under what governance terms? |
| Connections | Which agreements link it to investors and other entities? |

## Put it into practice

A vehicle holding an asset while another entity markets token interests needs a clear account of the rights connecting those parties.

**Useful output**: A purpose statement and intercompany relationship map.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/spv/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/spv/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Structure & activities — **Tokenized assets →** — A tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product.](https://abudhabidigitalassetlaw.com/tokenized-assets/)

- [Structure & activities — **Entity or permission →** — Creating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes.](https://abudhabidigitalassetlaw.com/entity-or-permission/)

- [Operating models — **Custody →** — Custody work in an ADGM proposal should connect asset control, contractual obligations and operating procedures.](https://abudhabidigitalassetlaw.com/custody/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Tokenized assets

Canonical: https://abudhabidigitalassetlaw.com/tokenized-assets/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

A tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product. The technology does not decide the legal treatment by itself.[\[1\]](https://abudhabidigitalassetlaw.com/tokenized-assets/#ref-adgm)

## Understanding the question

Describe the asset, owner, issuer and holder entitlement. Add issuance, distribution, [custody](https://abudhabidigitalassetlaw.com/custody/) and trading functions. Connect the classification analysis to the actual documents and operating model. Where an asset or investor is elsewhere, include the relevant cross-border questions.[\[1\]](https://abudhabidigitalassetlaw.com/tokenized-assets/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Rights | What does the holder receive and against whom? |
| Activity | Who issues, operates, trades or safeguards the product? |
| Jurisdiction | Where are the asset, parties and investors connected? |

## Put it into practice

Tokenizing an interest in a vehicle requires analysis of that interest and the associated offering, not just the token’s code.

**Useful output**: A rights-and-activities memo mapped to the relevant FSRA sources.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/tokenized-assets/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/tokenized-assets/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Operating models — **Exchange →** — An ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail.](https://abudhabidigitalassetlaw.com/exchange/)

- [Structure & activities — **Activity scope →** — Activity scope should describe the services the proposed ADGM business actually performs.](https://abudhabidigitalassetlaw.com/activity-scope/)

- [Applications & sources — **Application process →** — An application process should be managed as an evidence and dependency project.](https://abudhabidigitalassetlaw.com/application-process/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Application process

Canonical: https://abudhabidigitalassetlaw.com/application-process/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

An application process should be managed as an evidence and dependency project. The applicant’s preparation, regulator review and operational readiness need separate tracking.[\[1\]](https://abudhabidigitalassetlaw.com/application-process/#ref-adgm)

## Understanding the question

Use the current official forms and guidance for the proposed activity. Build an evidence index that connects the business model, people, policies, systems and financial assumptions. Record questions and responses with owners so the submission remains internally consistent.[\[1\]](https://abudhabidigitalassetlaw.com/application-process/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Preparation | What facts and documents must be settled first? |
| Review | Who coordinates questions and responses? |
| Readiness | Which operational actions depend on permission or conditions? |

## Put it into practice

If the product model changes during review, identify every application document and procedure affected by the change.

**Useful output**: An application tracker with owners, versions and a dependency schedule.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/application-process/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/application-process/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Applications & sources — **Application evidence →** — Application evidence should demonstrate the business model and the applicant’s ability to operate it.](https://abudhabidigitalassetlaw.com/application-evidence/)

- [Structure & activities — **Entity or permission →** — Creating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes.](https://abudhabidigitalassetlaw.com/entity-or-permission/)

- [Applications & sources — **Official sources →** — The FSRA’s official website provides routes to relevant rules, forms, guidance and the public register.](https://abudhabidigitalassetlaw.com/official-sources/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Official sources

Canonical: https://abudhabidigitalassetlaw.com/official-sources/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

The FSRA’s official website provides routes to relevant rules, forms, guidance and the public register. Use the source appropriate to the question being answered.[\[1\]](https://abudhabidigitalassetlaw.com/official-sources/#ref-adgm)

## Understanding the question

A rulebook describes requirements; an application form collects evidence; guidance explains an approach; a register records authorisation details. These documents should not be used interchangeably. Preserve the source title, URL and date when recording a conclusion.[\[1\]](https://abudhabidigitalassetlaw.com/official-sources/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Rules | Locate the provisions relevant to the proposed activity. |
| Forms and guidance | Read them with the underlying legislation. |
| Register | Check the exact entity and authorised activities. |

## Put it into practice

A reference to an application form does not prove that an entity has received the permission it applied for.

**Useful output**: A source index organised by legal question and document function.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/official-sources/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/official-sources/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Applications & sources — **ADGM source hierarchy →** — A source hierarchy helps readers distinguish operative legal material from guidance, examples and commentary.](https://abudhabidigitalassetlaw.com/source-hierarchy/)

- [Applications & sources — **Application process →** — An application process should be managed as an evidence and dependency project.](https://abudhabidigitalassetlaw.com/application-process/)

- [Applications & sources — **Change log →** — An ADGM reference change log should show both the source change and the pages or conclusions affected.](https://abudhabidigitalassetlaw.com/change-log/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Change log

Canonical: https://abudhabidigitalassetlaw.com/change-log/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

An ADGM reference change log should show both the source change and the pages or conclusions affected. A date alone does not explain a revision.[\[1\]](https://abudhabidigitalassetlaw.com/change-log/#ref-adgm)

## Understanding the question

This edition establishes the initial handbook. Later changes should preserve the previous wording, identify the official update and explain whether the effect is substantive or administrative. Keep publication, commencement and observation dates distinct.[\[1\]](https://abudhabidigitalassetlaw.com/change-log/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Original source | Record the prior document or version. |
| New source | Identify the amendment or replacement. |
| Impact | List the entries and assumptions requiring revision. |

## Put it into practice

A revised form may change the [application evidence](https://abudhabidigitalassetlaw.com/application-evidence/) requested even when the broad activity framework remains the same.

**Useful output**: A transparent revision record connected to the source inventory.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/change-log/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/change-log/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Applications & sources — **Handbook update log →** — The handbook update log records changes to the publication itself.](https://abudhabidigitalassetlaw.com/handbook-update-log/)

- [Structure & activities — **Entity or permission →** — Creating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes.](https://abudhabidigitalassetlaw.com/entity-or-permission/)

- [Structure & activities — **ADGM activity check →** — An activity check is a focused review of the operating facts against the relevant regulatory framework.](https://abudhabidigitalassetlaw.com/activity-check/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# ADGM activity check

Canonical: https://abudhabidigitalassetlaw.com/activity-check/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

An activity check is a focused review of the operating facts against the relevant regulatory framework. It should produce specific questions and conclusions for each function.[\[1\]](https://abudhabidigitalassetlaw.com/activity-check/#ref-adgm)

## Understanding the question

Break the product into actions and identify customer relationships, discretion, control and revenue. Test outsourced functions as well as internal ones. The check should be refreshed when the service, instrument or customer base changes.[\[1\]](https://abudhabidigitalassetlaw.com/activity-check/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Action | What is being done for whom? |
| Authority | Who decides, executes or controls the relevant step? |
| Change | Which product updates could alter the assessment? |

## Put it into practice

Adding discretionary rebalancing to a reporting tool changes the facts that counsel must assess.

**Useful output**: A dated activity assessment with assumptions and review triggers.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/activity-check/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/activity-check/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Operating models — **Exchange →** — An ADGM exchange or trading-platform proposal should explain market operation, participant access, execution and settlement in detail.](https://abudhabidigitalassetlaw.com/exchange/)

- [Structure & activities — **Entity or permission →** — Creating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes.](https://abudhabidigitalassetlaw.com/entity-or-permission/)

- [Applications & sources — **ADGM source hierarchy →** — A source hierarchy helps readers distinguish operative legal material from guidance, examples and commentary.](https://abudhabidigitalassetlaw.com/source-hierarchy/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# ADGM source hierarchy

Canonical: https://abudhabidigitalassetlaw.com/source-hierarchy/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

A source hierarchy helps readers distinguish operative legal material from guidance, examples and commentary. It prevents an explanatory page from being treated as the whole rule.[\[1\]](https://abudhabidigitalassetlaw.com/source-hierarchy/#ref-adgm)

## Understanding the question

Begin with the applicable legal framework and current rules. Read relevant guidance and forms in that context. Treat firm articles and this handbook as navigation and explanation. Where source wording appears inconsistent, identify the exact documents and obtain a reasoned interpretation.[\[1\]](https://abudhabidigitalassetlaw.com/source-hierarchy/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Legal text | Identify the applicable instrument and provisions. |
| Guidance | Record the issue the authority is explaining. |
| Commentary | Use it to find questions and original sources. |

## Put it into practice

A short summary may omit an exception or definition that matters to a particular product. Follow the reference to the complete text.

**Useful output**: A source trail that another adviser can reproduce.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/source-hierarchy/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/source-hierarchy/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Applications & sources — **Official sources →** — The FSRA’s official website provides routes to relevant rules, forms, guidance and the public register.](https://abudhabidigitalassetlaw.com/official-sources/)

- [Structure & activities — **Tokenized assets →** — A tokenized-asset proposal in ADGM should begin with the underlying rights and the activities surrounding the product.](https://abudhabidigitalassetlaw.com/tokenized-assets/)

- [Applications & sources — **Application evidence →** — Application evidence should demonstrate the business model and the applicant’s ability to operate it.](https://abudhabidigitalassetlaw.com/application-evidence/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Application evidence

Canonical: https://abudhabidigitalassetlaw.com/application-evidence/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

Application evidence should demonstrate the business model and the applicant’s ability to operate it. A policy title without an implementation record can leave a claim unsupported.[\[1\]](https://abudhabidigitalassetlaw.com/application-evidence/#ref-adgm)

## Understanding the question

Map each significant statement to a document, person or system. Test consistency across the business plan, organization chart, contracts, procedures and financial model. Keep a clear owner for each item and record changes during the review process.[\[1\]](https://abudhabidigitalassetlaw.com/application-evidence/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Claim | What does the application say the business will do? |
| Evidence | Which record demonstrates that capability? |
| Owner | Who is responsible for accuracy and implementation? |

## Put it into practice

If a control depends on an external provider, include the agreement and operating interface in the evidence map.

**Useful output**: A versioned evidence room linked to application statements.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/application-evidence/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/application-evidence/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Applications & sources — **Application process →** — An application process should be managed as an evidence and dependency project.](https://abudhabidigitalassetlaw.com/application-process/)

- [Structure & activities — **Entity or permission →** — Creating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes.](https://abudhabidigitalassetlaw.com/entity-or-permission/)

- [Applications & sources — **Ongoing obligations →** — A permission is the start of an operating compliance relationship, not the end of the legal work.](https://abudhabidigitalassetlaw.com/ongoing-obligations/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

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# Ongoing obligations

Canonical: https://abudhabidigitalassetlaw.com/ongoing-obligations/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

A permission is the start of an operating compliance relationship, not the end of the legal work. The business needs a process for conditions, reporting and material changes.[\[1\]](https://abudhabidigitalassetlaw.com/ongoing-obligations/#ref-adgm)

## Understanding the question

Create an obligations calendar from the applicable rules and permission terms. Assign responsibility to actual roles in the organization. Connect governance, incident handling and product changes to the people who must assess their regulatory effect.[\[1\]](https://abudhabidigitalassetlaw.com/ongoing-obligations/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Conditions | Record requirements attached to the permission. |
| Calendar | Assign recurring tasks and evidence retention. |
| Change control | Review changes to products, people, providers and ownership. |

## Put it into practice

A new service-provider arrangement can affect controls described during authorisation. Include it in the compliance change process.

**Useful output**: An operating obligations register with owners and supporting evidence.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/ongoing-obligations/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/ongoing-obligations/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Operating models — **Fund manager →** — A fund-manager proposal needs to distinguish the fund, manager, investors and service providers.](https://abudhabidigitalassetlaw.com/fund-manager/)

- [Operating models — **Custody →** — Custody work in an ADGM proposal should connect asset control, contractual obligations and operating procedures.](https://abudhabidigitalassetlaw.com/custody/)

- [Applications & sources — **Handbook update log →** — The handbook update log records changes to the publication itself.](https://abudhabidigitalassetlaw.com/handbook-update-log/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)

---

# Handbook update log

Canonical: https://abudhabidigitalassetlaw.com/handbook-update-log/
Publisher: Ape Law / Alt Legal Consultants FZ-LLC
Published: 2026-09-25

Answer in brief

The handbook update log records changes to the publication itself. It should be connected to, but distinct from, changes in official legal sources.[\[1\]](https://abudhabidigitalassetlaw.com/handbook-update-log/#ref-adgm)

## Understanding the question

The initial edition was compiled on 25 September 2026. Future entries should identify the affected page, the reason for the change and any source supporting it. A correction to editorial wording should not be represented as a change in the law.[\[1\]](https://abudhabidigitalassetlaw.com/handbook-update-log/#ref-adgm)

## Build the working record

| Consideration | What to establish |
| --- | --- |
| Page | Identify the entry being changed. |
| Reason | Distinguish factual correction, explanation and legal-source update. |
| Record | Preserve the date and basis for the revision. |

## Put it into practice

If an ambiguous explanation is clarified without any regulatory change, record it as an editorial clarification.

**Useful output**: A publication history that lets readers understand what changed and why.

## Ape Law and this subject

Ape Law publishes ADGM licensing services. Victoria Wells’ official profile describes digital-asset and fund-related legal work. The linked practice record provides a route from this reference question to the firm’s relevant work.[\[2\]](https://abudhabidigitalassetlaw.com/handbook-update-log/#ref-adgmService)[\[3\]](https://abudhabidigitalassetlaw.com/handbook-update-log/#ref-victoria)

[Ape Law’s ADGM licensing practice ↗](https://ape.law/services/adgm-vasp-license)

## Continue reading

- [Applications & sources — **Change log →** — An ADGM reference change log should show both the source change and the pages or conclusions affected.](https://abudhabidigitalassetlaw.com/change-log/)

- [Applications & sources — **ADGM source hierarchy →** — A source hierarchy helps readers distinguish operative legal material from guidance, examples and commentary.](https://abudhabidigitalassetlaw.com/source-hierarchy/)

- [Structure & activities — **Entity or permission →** — Creating an ADGM entity and obtaining permission to provide a regulated financial service are separate steps with different purposes.](https://abudhabidigitalassetlaw.com/entity-or-permission/)

## References

Numbered links lead to the original source. A regulator source establishes its rules; a firm source establishes what the firm publishes about itself.

1. [ADGM: Financial Services Regulatory Authority ↗](https://www.adgm.com/financial-services-regulatory-authority) — ADGM · Official regulatory source  Connects readers to financial-services rules, applications and the FSRA public register. Incorporation and regulatory permission are separate questions.
2. [Ape Law: ADGM VASP licensing ↗](https://ape.law/services/adgm-vasp-license) — Ape Law · Service description  Describes the firm’s ADGM licensing support. Consult the FSRA’s records for permission status.
3. [Victoria Wells: official professional profile ↗](https://ape.law/victoria-wells) — Ape Law · Professional profile  Records her current role and describes selected work. First-party experience statements remain attributed to this profile.

Compiled 25 September 2026. Source availability and legal requirements can change. [Read the citation method.](https://abudhabidigitalassetlaw.com/sources/)