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v1 ADGM + CBUAE [UAE] Travel Rule requirements

Written by Catarina Veloso

WIP Notice: The rules described in this article are not yet implemented in V2. The rules that are currently implemented for the AE jurisdiction in V2 are documented here.

These rules only apply to VASPs with AZ set as their Division or jurisdiction set as AE-AZ.

ADGM Travel Rule requirements are set forth in in Cabinet Decision No. (134) of 2025 and the Anti-Money Laundering and Sanctions Rules and Guidance (AML) (VER11.210526) ("ADGM Regulations").

CBUAE Travel Rule requirements are set forth in Cabinet Decision No. (134) of 2025 and The United Arab Emirates’ Virtual Assets Travel Rule ("CBUAE Regulations").

Threshold

Amount

Currency

Source

N/A

N/A

N/A

Travel Rule information-transmission obligations apply to any Virtual Asset Transfer, regardless of the amount. Under Article 28 of Cabinet Decision No. (134) of 2025, financial Institutions shall verify the accuracy of originator information in all international Wire Transfers equal to or exceeding AED 3,500. Conversely, for transfers below AED 3,500, institutions are not required to verify the accuracy of the transmitted data, unless there are suspicions of a crime.

Required Originator and Beneficiary information vs Notabene system

Party to the TX

Required information (*)

IVMS field

Required? (**)

Originator

Full name

name

Yes

Originator

Account number

accountNumber

Yes

Originator

Address

geographicAddress

Yes***

Originator

National identity number

nationalIdentification

OR

Originator

Customer identification number

customerIdentification

OR

Originator

Date and place of birth

dateAndPlaceOfBirth

OR

Beneficiary

Full name

name

Yes

Beneficiary

Account number

accountNumber

Yes

(*) Section 10.3.2 (k) and 10.3.3 (1) of the ADGM Regulations and Article 1, paragraph 2 of the CBUAE Regulations.

(**) YES = Required ; OR = Alternative fields
​(***) Under Article 1(2)(c) of the CBUAE Regulations, the geographic address is listed alongside other identifiers, namely the national identity number, customer identification number, and date and place of birth. The wording does not make clear whether all of these identifiers must be transmitted or whether institutions may provide only one of the identifiers listed in paragraph (c). Given that they are grouped within the same paragraph, they are understood to operate as alternatives to one another.

In any event, the originator’s geographic address is marked as mandatory because it is expressly required under Article 36(2)(a) of Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, which applies at the federal level.

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