CRYPTO BROKERAGE & CUSTODY LICENCE FOR THE FIRST DUAL-LICENSED FIRM IN ADGM
Re/think assisted BurjX Fund Management Limited in securing a ground-breaking ADGM Category 3A crypto brokerage and custody licence – the first of its kind to combine both permissions under a single authorisation from the Abu Dhabi Global Market.
The engagement enabled BurjX to set a new regulatory benchmark for compliant digital asset trading and custody in the MENA region.
Re/think supported BurjX Fund Management Limited (BurjX) with obtaining their ADGM Category 3A crypto brokerage and custody licence. BurjX is the first firm to secure a dual crypto brokerage and custody licence from the Abu Dhabi Global Market – marking a pivotal moment for regulated digital asset services in the region.
Re/think provided end-to-end regulatory advisory, licence application management, and compliance structuring to navigate the FSRA’s rigorous approval process.
With the MENA region ranked as one of the largest crypto markets globally, BurjX is now positioned to set a new benchmark for compliant crypto trading and custody – backed by one of the world’s most respected regulatory frameworks.
Client
BurjX Fund Management Limited
Licence
ADGM Category 3A
Focus
Crypto Brokerage & Custody
Market
Abu Dhabi / MENA
The Challenge
Obtaining a crypto brokerage and custody licence in the ADGM is one of the most demanding regulatory processes in the digital asset space. The FSRA applies institutional-grade standards to virtual asset service providers – requiring comprehensive governance frameworks, robust AML and compliance infrastructure, and significant capital commitments.
BurjX sought to achieve something no firm had done before: secure both brokerage and custody permissions under a single ADGM authorisation. This dual-licence structure required the applicant to satisfy overlapping but distinct regulatory requirements simultaneously – from capital adequacy and operational resilience to technology governance and client asset protection.
The application needed to demonstrate that BurjX could not only meet the FSRA’s baseline expectations, but exceed them – setting a precedent for how dual-licensed crypto firms would operate within the ADGM framework going forward.
Dual-licence complexity (brokerage + custody)
FSRA institutional-grade regulatory standards
No existing precedent for combined authorisation
Comprehensive AML, governance, and capital requirements
The Solution
Regulatory strategy and licence structuring
FSRA application management
Compliance framework design
Governance and operational readiness
Re/think delivered end-to-end advisory support to guide BurjX through the ADGM’s FSRA licensing process. This began with a detailed regulatory strategy that mapped the requirements for both brokerage and custody permissions, identifying where the two frameworks overlapped and where distinct compliance evidence was needed.
The team managed the full application lifecycle – from initial engagement with the FSRA, through the in-principle approval stage, to the satisfaction of all pre-conditions required for final authorisation. This included preparing comprehensive policy documentation, AML and counter-terrorism financing frameworks, technology governance protocols, and client asset segregation procedures.
Re/think also supported BurjX in building the internal governance and operational infrastructure required to meet the FSRA’s expectations for a live, dual-licensed operation – including board composition, key personnel appointments, and ongoing compliance monitoring frameworks.
Precedent-Setting Regulatory Engagement
As no firm had previously obtained a combined crypto brokerage and custody licence in the ADGM, Re/think worked closely with the FSRA to navigate uncharted regulatory territory. The engagement required proactive dialogue with the regulator, detailed submissions that anticipated supervisory concerns, and the ability to adapt the application in response to evolving expectations.
This collaborative approach helped shape the regulatory pathway for future dual-licensed applicants in the ADGM.
First-ever dual crypto licence in ADGM
Proactive FSRA engagement
Precedent-setting application approach
The Results
First-ever dual crypto brokerage and custody licence in ADGM
Full FSRA Category 3A authorisation secured
Comprehensive compliance framework approved by the regulator
Operational readiness achieved for live brokerage and custody services
New regulatory benchmark established for the MENA digital asset market
Why This Approach Worked
This engagement succeeded because it combined deep regulatory knowledge with hands-on application management. Rather than providing advice at arm’s length, Re/think embedded directly in the licensing process – acting as a strategic partner to BurjX from initial concept through to final FSRA authorisation.
The dual-licence structure demanded a level of regulatory precision that goes beyond standard crypto licence applications. Re/think’s familiarity with the ADGM’s FSRA framework, combined with practical experience in structuring compliance and governance for digital asset businesses, meant the application addressed regulatory expectations at every stage – reducing delays and building regulator confidence.
By helping BurjX navigate this process as the first firm to achieve dual authorisation, Re/think contributed to establishing a regulatory pathway that future crypto brokerage and custody applicants in the ADGM can follow.
Case Study Summary
What was done: End-to-end regulatory advisory and licence application management for an ADGM Category 3A crypto brokerage and custody licence
Who it helped: BurjX Fund Management Limited – the first firm to secure a dual crypto brokerage and custody licence in the Abu Dhabi Global Market
What problem was solved: Navigating a complex, precedent-setting regulatory process with no existing framework for combined brokerage and custody authorisation in ADGM
What result was achieved: Successful licensing as the first dual-authorised crypto brokerage and custody firm in ADGM, establishing a new benchmark for regulated digital asset services in the MENA region
Crypto Brokerage & Custody Licensing FAQs for the ADGM
What is a dual crypto brokerage and custody licence in the ADGM?
A dual licence authorises a single firm to both broker crypto asset transactions and provide custody services for digital assets under one ADGM regulatory approval. This means the firm can facilitate client trades and securely hold client assets within a single regulated entity – streamlining operations while meeting the FSRA’s standards for both activities.
What are the key requirements for an ADGM crypto brokerage licence?
Applicants must demonstrate adequate capitalisation (typically starting from USD 500,000, subject to adjustment), a comprehensive AML and counter-terrorism financing framework, qualified key personnel including a Senior Executive Officer and Money Laundering Reporting Officer resident in the UAE, robust technology governance, and a clearly defined business model approved by the FSRA.
Why is the ADGM considered a leading jurisdiction for crypto regulation?
The ADGM was the first jurisdiction in the MENA region to introduce a bespoke regulatory framework for virtual asset activities. It applies institutional-grade standards across brokerage, custody, exchange, and asset management activities – giving licensed firms credibility with institutional investors, banking partners, and international counterparties.
How does crypto custody licensing differ from brokerage licensing in the ADGM?
While brokerage permissions cover dealing in and arranging transactions in crypto assets, custody licensing specifically covers the safekeeping and administration of client digital assets. Custody licensees must demonstrate additional operational resilience, client asset segregation procedures, and technology controls to protect stored assets.
How long does it take to obtain a crypto licence in the ADGM?
The timeline varies depending on the complexity of the application and the responsiveness of the applicant. A typical ADGM crypto licensing process takes between four and six months from initial FSRA engagement to final authorisation, though precedent-setting applications – such as a dual brokerage and custody licence – may require additional time due to the regulatory dialogue involved.
