The Riffle
The Dubai Financial Services Authority (DFSA) has published the findings of its latest Conduct Supervisory Pulse examining Personal Account Dealing (PAD) across brokerage firms operating in the Dubai International Financial Centre (DIFC).
The review comes at a time when the DIFC brokerage sector is expanding rapidly, with authorised firms increasing significantly over recent years alongside substantial growth in profitability. As firms scale their operations, the DFSA has made it clear that internal controls governing employee trading must evolve accordingly.
Rather than viewing Personal Account Dealing as a standalone compliance obligation, the regulator positions it as an essential component of market integrity, conflict management and corporate governance.
Key Highlights
A rapidly growing market requires stronger controls
The DFSA notes that the brokerage sector has expanded considerably, increasing from 49 authorised firms in 2022 to 72 firms by March 2026. As firms grow in size, complexity and product offerings, governance frameworks must mature at the same pace.
The regulator expects Personal Account Dealing controls to be proportionate to each firm’s business model, operational complexity and conduct risks.
Personal Account Dealing frameworks remain inconsistent
The thematic review identified considerable variation across firms.
Among the findings:
18% of firms did not have documented PAD policies and procedures.
32% did not maintain a Personal Account Dealing register.
Many firms applied different approval requirements depending on transaction types, creating inconsistent oversight.
The DFSA stresses that effective policies should clearly define employee obligations, connected persons, covered instruments, blackout periods, holding requirements and disclosure expectations while remaining flexible enough to accommodate business growth and emerging asset classes such as digital assets.
Self-declarations alone are no longer sufficient
One of the strongest supervisory messages relates to monitoring.
The DFSA observed that many firms continue to rely heavily on employee declarations without independently verifying trading activity.
The regulator instead highlights stronger practices such as:
automated trade feeds from approved brokers;
post-trade surveillance;
comparison of employee trades against client activity;
monitoring for potential front-running or misuse of confidential information; and
surveillance of electronic communications where appropriate.
The expectation is that firms move from trust-based processes towards evidence-based oversight.
Governance must provide meaningful oversight
Senior management and Boards are expected to receive meaningful Management Information (MI) rather than simple confirmation that employees have completed annual declarations.
Effective reporting should include:
volume and nature of PAD requests;
breaches and their severity;
emerging conduct trends; and
risk indicators that enable management to assess the effectiveness of controls.
The review suggests that governance should focus on understanding trading behaviour rather than merely confirming policy compliance.
Compliance should test controls, not just documentation
The DFSA expects PAD to form part of firms’ Compliance Monitoring Programmes and internal audit activities.
Compliance functions should periodically test whether controls operate effectively in practice instead of simply confirming that declarations have been signed.
Similarly, training should extend beyond a “read and acknowledge” exercise by assessing employee understanding and tailoring content to the firm’s specific risks.
Record keeping remains a regulatory priority
Firms are required to maintain Personal Account Dealing records for at least six years.
Comprehensive registers should include:
employee attestations;
pre-clearance approvals;
executed trades;
identified breaches; and
supporting evidence demonstrating oversight.
The review identified examples of incomplete records and instances where firms reported no breaches despite evidence suggesting otherwise.
Why this matters
The DFSA’s review demonstrates that Personal Account Dealing is increasingly being viewed as an indicator of a firm’s overall governance culture.
Weak PAD frameworks can expose firms to conflicts of interest, insider dealing concerns, market abuse risks and regulatory scrutiny. Conversely, firms that invest in independent surveillance, robust governance and effective compliance testing are better positioned to demonstrate a strong conduct culture.
For brokerage firms operating in the DIFC, this review provides a practical benchmark against which existing PAD frameworks should be assessed.
The Riffle Takeaway
The DFSA’s latest supervisory findings reinforce a broader regulatory trend: firms are expected to demonstrate that their compliance frameworks work in practice, not merely that policies exist on paper.
As supervisory engagement continues throughout 2026, brokerage firms should review whether their Personal Account Dealing framework is genuinely risk-based, independently monitored and capable of identifying misconduct before it becomes a regulatory issue.
With future phases of the thematic review expected to examine Best Execution, Communication Channels and Record Keeping, firms should view this as an opportunity to strengthen their wider conduct risk framework rather than addressing PAD in isolation.
