Client Assets

CLIENT ASSETS

Overview

The protection of Client Assets (Client Money, Client Investments, and Client Crypto Tokens) remains a regulatory priority for the DFSA.

We apply a risk-based approach to supervising Client Assets and have a low risk tolerance for any instances of misappropriation or mismanagement.

Under Principle 9 of the Principles for Authorised Firms (Customer Assets and Money), an Authorised Firm is required to arrange proper protection of Clients Assets when it is responsible for them.

Authorised Firms must properly safeguard Client Assets they hold and/or control on behalf of Clients in the course of, or in connection with, carrying on Investment Business, Operating a Crowdfunding Platform, Providing Money Services or undertaking Crypto Business in or from the DIFC.

Our approach to supervising Client Assets

The DFSA conducts an annual review of Client Money and Safe Custody Auditor’s Reports as part of our proactive approach to supervising compliance with Client Assets Rules.

These reports are a key source of supervisory insight into the Client Assets arrangements of Authorised Firms.

Where breaches of the Client Assets Rules are identified, the DFSA follows up with Authorised Firms, applying a risk-based approach. 

What Authorised Firms are required to do

If your business model involves holding and/or controlling Client Assets, you should ensure that you have the appropriate permissions to do so. This requires a Client Assets endorsement on your Licence (General Module (GEN) 2.2.10A).

Authorised Firms that hold and/or control Client Assets must follow rules set out in the DFSA Rulebook, in particular the Client Money and Safe Custody Provisions in the Conduct of Business Module. In addition, you should:

• Submit the required B420 Form on Client Assets-related activities in the Electronic Prudential Reporting System (EPRS); 
• Ensure you comply with the Audit reporting requirements for Client Assets, as set out in GEN Chapter 8. This includes the timely submission of the Client Assets Auditor’s Report and the full and accurate completion of the Annual Report submission form;
• Promptly notify the DFSA of any breaches of the Client Assets Rules and the remedial action taken or underway.  

Updates to the Client Assets regime

In August 2024, the DFSA published Consultation Paper No 160 (CP160), outlining proposed changes to the Client Assets regime.

On 14 March 2025, we issued a Feedback Statement on the public comments received on CP160, alongside relevant updates to the DFSA Rulebook.

The revised rules will come into effect on 1 January 2026.

Please refer to our Dear SEO Letter and Frequently Asked Questions in relation to the updates to the Client Assets regime.

Contact Us

If you are an Authorised Firm, general queries about Client Assets should be submitted using the DFSA Supervised Firm Contact Form on the DFSA ePortal.

For queries specifically related to the updates to the Client Assets regime, please select option ‘7. Others – Client Assets Regime Implementation’ when submitting your query.

If you do not have access to the DFSA ePortal, please use the general enquiry section on the DFSA website.