ADGM Enforcement and Disqualification Manual

Registration Authority

October 2025

TABLE OF CONTENTS

Underlying factors ...49 Key factors ...50 Aggravating factors ...51 Mitigating factors ...51 Penalties for breaching disqualification orders and undertakings ...52 Personal liability for company’s debts ...52 Register of disqualification orders ...53 CHAPTER 11 – PUBLICITY ...54 Introduction ...54 Publicity about ongoing matters ...54 Publication of Notices ...54 Publication about proceedings ...55 DISCLAIMER ...57 Annex 1 – Registration Authority Investigation Process Flow Diagram ...58 Annex 2 – Tier 1 Contravention Flow Diagram (after detection) ...59 Annex 3 – Tier 2 Contravention Flow Diagram (after detection) ...60

CHAPTER 1 – INTRODUCTION

Introduction

1.1 This Enforcement and Disqualification Manual (the “Manual”) provides information on the policies, processes and procedures of ADGM’s Registration Authority in relation to the exercise of its disqualification and enforcement powers and rela...