The Dubai Financial Services Authority (DFSA) has published its inaugural Conduct Supervisory Pulse, outlining key findings from a thematic review of Personal Account Dealing (PAD) frameworks across brokerage firms in the Dubai International Financial Centre (DIFC).
The Pulse forms part of a wider programme of deep‑dive supervisory sessions jointly undertaken by DFSA’s Conduct Supervision and Markets teams throughout 2026, focusing on oversight of the trading environment. PAD was identified as one of three priority areas, alongside best execution and communication channels/record keeping.
The review comes amid rapid growth in the DIFC brokerage sector, with authorised firms increasing by more than 60% since 2022, alongside significant rises in headcount, profitability, and transaction volumes. DFSA stressed that effective PAD controls are essential to protect investors and maintain market integrity as firms expand.
Key observations included the importance of proportionality, ensuring PAD frameworks are aligned to the scale, complexity, and risk profile of each firm. Positive indicators highlighted across firms included:
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Comprehensive and tailored PAD policies.
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Centralised pre‑trade approval processes.
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Periodic compliance monitoring.
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Clear escalation and breach management.
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Use of management information for Board oversight.
Areas requiring enhancement included over‑reliance on employee declarations, limited post‑trade monitoring, and weak record‑keeping. The Pulse sets out practical examples across six areas: policies and procedures, governance and oversight, monitoring and surveillance, compliance, training and awareness, and record keeping.
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