Know where you stand — before the regulator asks.
RegXperience is a recurring self-assessment for ADGM AML/TFS: measure your firm against every applicable Rulebook chapter, as often as you want, with evidence-backed scoring (verdict × maturity, per requirement, every claim cited) — then auto-draft the reports the regime actually requires — gap register and remediation plan included
Google sign-in · unlimited runs · content pinned to VER11.210526
Three artifacts are mandatory. Everything else is rhythm.
Vendors love to sell “7 regulatory reports a year.” The Rulebook doesn't say that — and your credibility with the FSRA depends on knowing the difference.
What feeds what: the Rule 4.1.1(4) effectiveness review supplies item (a) of each MLRO report; the MLRO reports and the gap register supply the Annual AML Return working paper; senior management's assessment of each report is itself a record the FSRA receives (Rule 12.4.2–12.4.3).
Your entity type decides which chapters apply.
Stage 1 of every assessment is scoping — the anchor generic GRC tools don't have.
Authorised Person / Recognised Body
The widest scope — Chapters 1–14, correspondent banking and travel-rule questions included when you declare the exposure.
DNFBP
Adds Chapter 15 registration; the correspondent-banking chapter falls away. Category captured per Rule 3.2.1.
Representative Office
No customers — Chapters 7–10 don't apply, giving the shortest assessment.
Non-Profit Organisation
Assessed against Chapter 16 only: control, purpose and six-year fund traceability.
The 16-chapter Rulebook, as 67 assessable requirements.
Each question carries its rule citations, a compliant / partially / non-compliant rubric, the evidence it expects — and, where the ADGM RA published them, the peer benchmark.
D1Governance, responsibility & compliance culture
Ch. 1 · 4.14 questions
D2Group policies & record-keeping
§ 4.3 · 4.54 questions
D3Annual AML Return readiness & high-risk jurisdictions
§ 4.6 · 4.93 questions
D4Risk-based approach
Ch. 53 questions
D5Business risk assessment
Ch. 67 questions
D6Customer risk assessment
Ch. 74 questions
D7CDD, EDD, SDD, ongoing monitoring & PEPs
Ch. 88 questions
D8Third-party reliance & outsourcing
Ch. 93 questions
D9Correspondent banking, transfers & prohibited accounts
Ch. 105 questions
D10Targeted financial sanctions
Ch. 115 questions
D11MLRO appointment, standing & reporting
Ch. 125 questions
D12AML/TFS training & awareness
Ch. 133 questions
D13SAR/STR governance
Ch. 146 questions
D14DNFBP registration & supervision
Ch. 152 questions
D15Non-profit organisation obligations
Ch. 162 questions
D16Annual effectiveness review
Rule 4.1.1(4)3 questions
The regime penalises inadequate controls — not just actual laundering.
Three findings from the public record shaped how this product scores.
Systems-and-controls adequacy is the test.
In the FSRA's December 2024 settlement with an ADGM firm over AML systems-and-controls failures, the investigation "did not identify any instances of actual money laundering." The failures alone were enough. So every requirement here is scored on design and operating effectiveness — a 1–5 maturity rating beside the verdict.
Prompt remediation is worth real percentage points.
The same settlement carried a 20% discount for early settlement and a further 10% for cooperation and prompt remedial action. That is why the gap register — owners, due dates, tracked closure — is a first-class surface here, not an export.
The RA already told you the questions.
The ADGM Registration Authority's 2024 DNFBP thematic review — a 40-question questionnaire across 202 firms — says firms should "utilize this review as a self-assessment tool." Its published good-practice pairs and benchmark percentages (94% documented BRA methodology, 74% annual BRA review, 95% senior-management approval…) are seeded into the rubrics you'll answer against.
Everything sign-in unlocks, in three phases.
1 · Scope & assess
- Stage 1 scoping — entity type + exposures switch domains on/off (Rule 1.2.1)
- Unlimited versioned assessment runs; “reassess since last run” carries answers for delta review
- Per-requirement verdict + 1–5 maturity + rationale, every question cited
2 · Track & remediate
- Evidence locker — sha-256 fingerprints, Rule 4.5.1 six-year retention clocks
- Document Quality Evaluation Engine scores whether evidence satisfies its requirement
- Conflicting self-ratings flagged for human confirmation; gap register with severity, owner, due date
3 · Report & attest
- MLRO semi-annual report — Rule 12.4.1(a)–(f) auto-drafted from run data
- Annual AML Return working paper + effectiveness-review working paper
- Quarterly board MI pack · everything exports to Word with sign-off trails
From sign-in to a signed-off report.
01Scope the firmRule 1.2.1
Entity type, DNFBP category, correspondent-banking / virtual-asset exposure. Output: your applicability filter.
02Assess domain by domainCh. 4–16
Answer each in-scope requirement: verdict, maturity, rationale. An honest N/A needs a justification a supervisor could read.
03Attach evidenceRule 4.5.1
Upload the BRA, policies, training logs. The engine scores each document against its requirement and flags wishful ratings.
04Complete & score the run
Weighted compliance % and maturity per domain; every adverse verdict becomes a gap with severity, owner and due date.
05Generate the reportsRules 12.4.1 · 4.6.1 · 4.1.1(4)
MLRO report, Return working paper, effectiveness review, board pack — drafted from your data, edited by you, signed off on the record.
MLRO · deputy · compliance in-charge — one workspace
What this product deliberately does not do: no live CDD, screening or transaction monitoring; no SAR/STR filing to goAML; no direct FSRA Connect submission. RegXperience assesses and reports on your AML programme — it does not run it. And because the FSRA does not publish the Return's field-by-field form, our working paper is a reasoned Rulebook mapping, labelled as such.
ADGM AML and Sanctions Rules and Guidance, VER11.210526 — the primary text. It supersedes every summary in this product.
ADGM AML supervision hub · FSRA Connect (Return filing) · UAE FIU goAML (SAR/STR filing).
Content pinned to VER11.210526 · re-validated on each ADGM update