adgm

Why ADGM

Abu Dhabi Global Market is Parthenon Fi's primary jurisdiction for four reasons:

1. English Common Law: ADGM operates under English common law, meaning the GMSLA is directly enforceable without legal translation risk

2. Comprehensive Digital Asset Framework: FSRA has defined clear categories for Virtual Assets, Fiat-Referenced Tokens, and Digital Securities

3. Institutional Ecosystem: Binance, Laser Digital (Nomura), Zodia Custody (Standard Chartered), Franklin Templeton, and BlackRock all have ADGM presence

4. June 2025 Amendments: FSRA explicitly brought VA lending, borrowing, and staking under regulatory scope

FSRA June 2025 Amendments

The FSRA implemented amendments on June 10, 2025 that directly affect Parthenon's licensing:

• Shifted from approval-based to notification/self-assessment for Accepted Virtual Assets

• Expressly prohibited privacy tokens and algorithmic stablecoins

• Raised custodian minimum capital to AED 5 million

• Explicitly brought VA lending, borrowing and staking under regulatory scope as licensed activities

All entities engaged in these activities from ADGM now require an FSRA Financial Services Permission.

Licensing Pathways

Option A: Tech Startup Licence (Immediate)

Detail	Value
Cost	USD 1,500/year via Hub71
Timeline	2–4 weeks
Scope	Full commercial rights, 100% foreign ownership, visa access
Limitations	Cannot conduct regulated financial activities

Use for Parthenon: Establish ADGM entity immediately. Begin custodian integration, prepare FSRA application.

Option B: FSRA Financial Services Permission (Production)

Option C: FSRA RegLab Sandbox (Recommended Path)

Relevant Regulated Activities

For Module 2, Parthenon would seek authorization for:

• Arranging Deals in Investments: Matching lenders with borrowers via RFQ system and orderbook

• Advising on Investments or Credit: Recommending lending/credit products to institutional counterparties

• Operating a Multilateral Trading Facility: Running secondary markets for Loan Position Tokens

• Managing Assets: Managing tokenized credit portfolios (vault products, structured tranches)

ADGM Institutional Ecosystem

Licensed entities representing immediate partnership and distribution opportunities:

Entity	License / Activity	Relevance to Parthenon
Binance	Full license (Dec 2025) — exchange, clearing, broker-dealer	Distribution, liquidity
Laser Digital / Nomura	Broker-dealer & AM (FSP #240029)	Institutional distribution
Zodia Custody	Standard Chartered subsidiary — custodian	Primary ADGM custodian integration
Franklin Templeton	MoU with ADI Foundation	Tokenized funds as potential collateral
BlackRock	MoU with ADI Foundation	Tokenized asset structures
QCP Group	Full authorization (Sep 2025)	Trading counterparty

Recommended Timeline

1

Phase 1 (Months 1–3)

• Obtain Tech Startup Licence.

• Initiate FSRA inquiry.

• Engage James Lake (ADGM Director of Legal).

• Establish Zodia custody relationship.

2

Phase 2 (Months 3–9)

• Apply to FSRA RegLab.

• Run pilot transactions with 2–3 institutional counterparties.

• Pursue tri-party custodial agreements.

3

Phase 3 (Months 9–18)

• Transition from RegLab to full FSRA FSP.

• Scale custodian integrations.

• Launch Module 2 in production.