• Test 1 Test 1: The Ownership Test

    The ownership test is to identify the individual who ultimately own the ADGM Entity. Ultimate owners are considered to be a registrable beneficial owner and their information and identification documents must be provided to the Registration Authority at the time of application and must be kept up-to-date throughout the lifecycle of ADGM Person.
    To help you identify the registrable beneficial owners, please refer to the illustration below. Registrable beneficial owners are identified through grey boxes.

    • Direct Ownership

      In this example, Individual 1 owns 100% of the ADGM Entity. He is the beneficial owner.

      In this example, Individual 1 and Individual 2 are direct owners of ADGM Entity. Both individual are the beneficial owners.

    • Indirect Ownership

      In this example, Individual 1 is the indirect owner and beneficial owner of the ADGM Entity.

      In this example, Individual 1 and Individual 2 are indirect owners and beneficial owners of the ADGM Entity.

    • Multiple Indirect Ownership

      In this example, there are multiple levels of indirect ownership. The two beneficial owners are clearly marked in grey boxes. In this case, Individual 4 has a 32.75% interest in ADGM Entity (50% x 65.5% = 32.75%) and Individual 1 has 50%.
      Calculating shareholdings: a reference in this Guidance Note to holding shares in an ADGM Person or other legal entity is to holding a right to share in the capital or, as the case may be, profits of that person or other entity, and a reference to holding “more than 25% of the shares” in that ADGM Person or other legal entity is to holding a right or rights to share in more than 25% of the capital or, as the case may be, profits of that person or other entity.

       

      If no registrable person can be identified under Test 1, Test 2 also needs to be considered.