In 2024, the Abu Dhabi Global Market (“ADGM”) further enhanced transparency, accountability, and market integrity within the financial freezone by introducing the Whistleblower Protection Regulations 2024 (the “Regulations”). In brief, those Regulations require certain entities registered or licensed to operate or conduct any activity within the ADGM to implement arrangements for handling whistleblowing, including having appropriate written policies and procedures, and to maintain related records for at least six years. The Regulations also afforded the Registrar of the ADGM the power to issue censures, impose financial penalties, or suspend or withdraw licenses for contraventions.
Importantly, ADGM entities have until May 31, 2025—approximately just four more months—to implement those arrangements. The clock is ticking.
The New Whistleblower Framework in Overview
On March 7, 2024, the ADGM issued a Consultation Paper (the “Paper”)[1] proposing the implementation of a comprehensive whistleblower framework and soliciting comment.[2] Then on July 5, 2024, the ADGM issued the Regulations,[3] significantly developing the scope of whistleblower protections within the ADGM.[4] Finally, on July 11, 2024, the ADGM issued Guidance on the Regulations (“Guidance”),[5] designed to assist with implementation.
Importantly, the Regulations require Global Market Establishments (“GMEs”)[6] to implement arrangements for handling Protected Disclosures[7] and to keep related records for at...
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