Tom Bicknell, Pinsent Masons' Middle East head of finance, added: "The new ADGM digital banking licenses offer an interesting proposition and investment opportunity for financial institutions not already established in the UAE and/or the Middle East. The ADGM's direct application of English common law offers legal certainty not commonly associated with businesses operating out of the Middle East, and therefore presents a compelling proposition for local and international players looking to exploit this area of financial services."
Applicants for an ADGM digital banking licence can expect "appropriate" assessment depending on the type of product they intend to offer, according to guidance published by the FSRA. For this reason, it has suggested that firms only seeking to offer innovative payment solutions such as e-wallets, tokens and stored value cards should instead consider another form of licence that will attract a lower regulatory and capital burden.
The FSRA will require applicants of the new digital banking licence to hold USD$10 million in base capital. They will also be required to demonstrate robust governance structure, compliance and risk management policies, IT security measures and certain mandatory senior management appointments as part of their application.