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On June 29, 2026, the Dubai Financial Services Authority (DFSA) published its first Conduct Supervisory Pulse, presenting key observations from a thematic review of Personal Account Dealing (PAD) arrangements across brokerage firms operating in the Dubai International Financial Centre (DIFC). The review forms part of a broader supervisory programme conducted jointly by DFSA Conduct Supervision and Markets teams throughout 2026, focusing on oversight of the trading environment. The thematic review addresses PAD as one of three priority areas for brokerage firms, with best execution and communication channels and record keeping to follow. The review was undertaken against significant sector growth; since 2022, the number of authorised brokerage firms in DIFC has increased by more than 60 percent, alongside substantial increases in headcount, profitability, and transaction volumes. The DFSA identified proportionality as a key observation, emphasising that firms should ensure their PAD frameworks remain aligned to the nature, scale, and complexity of their business activities, products, employee roles, and risk profile. The Pulse highlights positive indicators observed across firms of varying scale and complexity, including comprehensive and tailored PAD policies, centralised pre-trade approval processes, periodic compliance monitoring, clear breach escalation procedures, and use of management information for senior management and Board oversight. The review also identified areas requiring 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, management information, and oversight; monitoring and surveillance; compliance oversight and monitoring; training and awareness; and record keeping. The DFSA encourages relevant firms to assess the observations and consider enhancements to their PAD frameworks. Subsequent phases of the thematic review will address best execution and communication channels and record keeping, with further observations to be shared as the review progresses.