Dubai Financial Services Authority publishes first Conduct Supervisory Pulse on personal account dealing controls at DIFC brokerage firms

The Dubai Financial Services Authority has published its first Conduct Supervisory Pulse, setting out observations from a thematic review of Personal Account Dealing arrangements at brokerage firms in Dubai International Financial Centre. The review found that firms need PAD frameworks that are proportionate to the nature, scale and complexity of their business, products, employee roles and risk profile, as expanding trading activity increases the importance of controls over employees' personal trading. Against a backdrop of more than 60% growth in authorised brokerage firms since 2022, the Pulse highlights stronger practices such as tailored PAD policies and procedures, centralised pre-trade approval, periodic compliance monitoring, clear escalation of breaches, and management information that supports senior management and board oversight. It also points to areas for improvement, including over-reliance on employee declarations, limited post-trade monitoring and poor record-keeping. The observations are organised across six areas: policies and procedures, governance management information and oversight, monitoring and surveillance, compliance oversight and monitoring, training and awareness, and record keeping. The publication forms part of a broader 2026 programme of deep-dive supervisory engagement by the DFSA's Conduct Supervision and Markets teams on oversight of the trading environment. The remaining phases will cover best execution and communication channels and record keeping, with further observations to be published as the review progresses.