The Dubai Financial Services Authority (DFSA) has published its first Conduct Supervisory Pulse (Pulse), sharing key observations from a thematic review of Personal Account Dealing (PAD) arrangements across brokerage firms in Dubai International Financial Centre (DIFC).
This is part of a broader programme of deep-dive supervisory engagement sessions being undertaken jointly by DFSA Conduct Supervision and Markets teams throughout 2026 under the DFSA’s thematic review on oversight of the trading environment.
Effective oversight of the trading environment in brokerage firms is critical for protecting investors and maintaining market integrity. The first phase of the review focuses on PAD as one of three key priority areas relevant to brokerage firms’ oversight of the trading environment, with best execution and communication channels and record keeping to follow shortly.
The review was conducted against a backdrop of continued growth across the DIFC brokerage sector. Since 2022, the number of authorised brokerage firms has increased by more than 60%. Headcount, profitability, and transaction volumes have also increased significantly.
As firms’ trading activities continue to expand, having effective controls and monitoring of personal trading by employees is an essential component of both broader trading oversight and market conduct risk arrangements.
A key observation from the review was the importance of proportionality. As the sector continues to grow and evolve, firms should ensure that their PAD frameworks remain aligned to the nature, scale, and complexity of their business activities, products, employee roles and risk profile.
The Pulse highlights examples of positive indicators observed across firms varying in scale and complexity. These included:
- Comprehensive and tailored PAD policies and procedures;
- Centralised pre-trade approval processes;
- Periodic compliance monitoring;
- Clear escalation and management of breaches; and
- Use of management information to support senior management and Board oversight.
The review also identified areas where firms should consider strengthening their PAD arrangements, including to address over-reliance on employee declarations, limited post-trade monitoring, and poor record-keeping practices.
The publication includes practical examples of positive indicators and indicators requiring enhancement across six key areas:
- Policies and procedures;
- Governance, management information, and oversight;
- Monitoring and surveillance;
- Compliance oversight and monitoring;
- Training and awareness; and
- Record keeping.
The DFSA encourages all relevant firms to consider the observations outlined in the Pulse and assess whether enhancements to their own PAD frameworks may be appropriate.
The remaining phases of the thematic review will focus on best execution, and communication channels and record keeping, with further observations to be shared as the review progresses.
