Write the stage, the recipient, and the contract that limits the file.
List what you will show at each stage, who receives it, and which customer contract, employment agreement, or confidentiality term forbids that disclosure. A data room is a set of permissions. It is not a courtesy.
Aaron Harris treats concealment of identity and of whose money is being invested as a reason to be suspicious. That is about the investor, not a rule for your customer files. Use it only as a reminder that you can stage what you reveal while checks are unfinished. Authenticate the recipient on a channel you opened. The ADGM alert of 10 April 2025 separates a company register from a permission register, and neither proves the person in the inbox.
Question. What should you share at each diligence stage, and which customer or third-party restrictions govern that access?
Harris writes that most founders do not get to choose whose money they take. He discusses AngelList syndicates and special purpose vehicles that raise from outside limited partners, and says those forms are not bad in themselves. Concealment of who someone is, and of whose money is being invested, is a reason to be suspicious. He does not publish a four-way taxonomy of capital sources.
The FSRA warned that fraudsters misuse names and logos of FSRA-licensed firms. Only firms authorised by the FSRA may undertake regulated activities in ADGM. Check the ADGM Registration Authority public register for incorporation, and the FSRA public register for a Financial Services Permission. One register does not answer the other.