DFSA sets Personal Account Dealing oversight expectations for brokerage firms

The Dubai Financial Services Authority (DFSA) has published its first Conduct Supervisory Pulse, sharing key observations from a thematic review of Personal Account Dealing (PAD) arrangements across brokerage firms in the DIFC. The review was conducted as part of a broader programme of supervisory engagement throughout 2026, focusing on oversight of the trading environment.

The DFSA noted that effective oversight of PAD is critical for protecting investors and maintaining market integrity. A key observation was the importance of proportionality: as the sector continues to grow, firms should ensure their PAD frameworks remain aligned to the nature, scale, and complexity of their business activities, products, employee roles and risk profile.

Positive indicators observed across firms included comprehensive and tailored PAD policies, 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 for strengthening, including over-reliance on employee declarations, limited post-trade monitoring, and poor record-keeping practices. The publication provides practical examples across six key areas: policies and procedures; governance and oversight; monitoring and surveillance; compliance oversight; training and awareness; and record keeping.