Regulation guide

ADGM Outsourcing Risk

Operationalize the ADGM Outsourcing Risk requirements—from regulatory obligations and evidence collection to vendor assessments, continuous monitoring, governance, and remediation workflows.

Overview

ADGM outsourcing requirements should be read in the current FSRA rulebook for the firm's activity. The core principle is accountability: an authorized firm remains responsible when regulated or important functions are performed by another party.

It applies to authorized firms, banks, and other regulated organizations in the UAE and requires organizations to identify, assess, govern, monitor, and manage risks introduced by third parties, outsourcers, and service providers throughout the entire relationship lifecycle.

Rather than prescribing identical controls for every relationship, the regulation emphasizes a risk-based approach, requiring organizations to apply governance, oversight, controls, monitoring, and due diligence according to the criticality and risk of each relationship.

This implementation guide explains what the regulation requires, how those requirements translate into operational controls and evidence, and how Halbarad helps organizations operationalize compliance through assessments, continuous monitoring, governance workflows, and supply chain risk intelligence.

Official Sources

Operationalization Requirements

  • Identify outsourced functions and service providers.
  • Assess materiality, regulated activity impact, data, and operational dependency.
  • Review contracts for confidentiality, audit, access, regulatory access, monitoring, continuity,

termination, and exit.

  • Monitor providers, issues, incidents, changes, and remediation.

Evidence Requirements

  • Outsourcing inventory and risk assessments.
  • Contract review and approval records.
  • Monitoring, incident, issue, and remediation records.
  • Continuity and exit evidence.

Common Gaps

  • Outsourcing analysis is not tied to regulated activities.
  • Regulatory access terms are assumed but not evidenced.
  • Exit plans do not match the actual service.

How Halbarad Helps

Halbarad helps maintain outsourcing records, provider evidence, downstream-party visibility, monitoring, issues, approvals, and audit trail.

Disclaimer

This guide is for general information only and is not legal advice. Review the official regulation, guidance, and supervisory materials, and consult qualified counsel or compliance advisors for your organization's specific obligations.