Ensuring employee personal trading compliance is critical for banks and financial services firms across the United Arab Emirates (UAE) to maintain market integrity, protect clients and the firm, and meet regulatory expectations.
To keep pace, the compliance team must actively monitor all employee trading activity, flagging breaches for investigation or enforcement.
Employee personal trading compliance in the UAE for financial services firms is overseen by key regulators—including the Securities and Commodities Authority (SCA), Dubai Financial Services Authority (DFSA) and the Virtual Assets Regulatory Authority (VARA) through a strict framework of licensing, conduct standards, and risk controls focused on trading activities, disclosure, and governance.
Read A Guide to Financial Services Regulators and Compliance Regulations in the Middle East
Regulatory Obligations Covering Employee Personal Trading Compliance in the UAE
Financial services employees, directors, and managers must comply with firm policies and regulator rules on personal trading, which include:
SCA Rulebook Conflicts of Interest Obligations
The SCA’s Rulebook includes Business Practice – Conditions for Providing Financial Service to a Client, which covers obligations including conflicts of interest and general conduct standards for licensed entities.
DFSA Conduct of Business Personal Trading Conditions
Under DFSA’s COB 6.2 – Personal Account Transactions the Conduct of Business module, the rules impose conditions, record-keeping and controls on personal trading by employees of authorized firms, imposing the following conditions:
Written notice & employee awareness
An Authorised Firm must issue a written notice to the employee specifying the conditions under which the employee may carry out personal account transactions, and make that notice part of the employment contract.
Written permission / firm approval
The employee must obtain written permission from the firm (for that specific transaction or in general) before executing a personal account transaction involving a regulated instrument or cryptocurrency token.
No conflict with duties to clients
The firm must ensure that any approved employee personal account transaction does not conflict with the firm’s duties to its clients.
Prompt notification/awareness
The firm must receive prompt notification or otherwise become aware of each employee’s personal account transactions.
Distinct account identification inside the firm
If an employee’s personal account transactions are conducted with the Authorised Firm, that account must be clearly identified and distinguishable from client accounts.
Record-keeping requirement
The firm must maintain adequate records of personal account transactions in accordance with the record-keeping provisions of COB 6.2.
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VARA / Virtual Assets regime in Dubai
The Dubai Virtual Assets Law (Law No. 4 of 2022) and Cabinet Resolutions 111 and 112 of 2022 establish VARA’s authority over regulated virtual-asset service providers (VASPs) in Dubai.
Within the VARA Rulebook, there is a requirement that “the Board shall implement rules to govern and monitor the transactions of Board members and its Staff” (i.e., insiders) under the Market Conduct Rulebook.
VARA’s Insider Lists rule requires VASPs to maintain updated insider lists of all persons with access to inside information, retain them for at least 8 years, and provide them to VARA on request.
VARA’s Insider Dealing rule defines prohibited behaviors involving inside information and requires that insiders not engage in transactions using inside information.
Read About Smarter Ethics and Conduct Risk Management for UAE Banks and Financial Services Firms
New Regulatory Developments in 2025 in the UAE Concerning Employee Personal Trading Compliance
- SCA Resolution No. 10 formalized the registration and licensing regime for “finfluencers,” requiring pre-approval and ongoing supervision for those advising or promoting securities-related trades on social platforms.
- VARA continues to update its personal trading guidelines for crypto and digital asset firms, which now require independent risk committees, trade approvals, and segregated client assets.
- VARA is evolving rules (sometimes referred to as “VARA 2.0”) that may impose stricter controls on margin trading, disclosure of leveraged positions, and tighter governance in digital asset trading.
- Regulators are paying greater attention to cross-frontier trading, insider leaks, and conflicts across traditional and crypto assets, requiring firms to unify their personal trading compliance frameworks.
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Best Practices for Employee Personal Trading Compliance Across the UAE
Best practices require employees to obtain pre-approval for trades, disclose personal trading activity, observe blackout periods, and report any conflicts of interest to ensure transparency and regulatory compliance.
- Obtain pre-approval (“pre-clearance”) from a compliance officer before making trades in financial instruments or securities.
- Disclose personal trading accounts and all trades periodically, including registration with the firm’s compliance register.
- Observe blackout periods around significant announcements, transactions, or market events to avoid conflicts with client or firm information.
- Report any conflicts of interest to supervisors and maintain a compliance record for regulators to review in case of audits or inspections.
Below are best practices for compliance to ensure effective oversight of employee personal trading, maintain regulatory compliance, and promote a strong culture of accountability:
- Review and update internal personal trading policies annually, ensuring all regulatory requirements and current best practices are addressed and communicated to employees.
- Train employees on recognizing and reporting conflicts of interest, the importance of pre-clearance, and conduct expectations during sensitive periods.
- Maintain robust compliance registers and conduct audits to ensure ongoing policy adherence and be ready for regulatory inspection
Robust monitoring of employee trading is essential for maintaining compliance and protecting market integrity. Compliance functions or internal audit teams should actively monitor trades, flag suspicious patterns, and investigate potential breaches to ensure compliance. Regulators, including the SCA, DFSA, and VARA, have broad powers to inspect, audit, impose fines, suspend or ban individuals, and sanction firms for non-compliance with regulations. This oversight is particularly critical for virtual-asset firms, where VARA relies on its Market Conduct rulebooks to assess staff conduct and prevent insider misuse. Together, these measures help ensure a culture of accountability, transparency, and regulatory adherence across the organization.
MyComplianceOffice Enables UAE Firms to Effectively Manage Employee Compliance and Employee Personal Trading
The MyComplianceOffice platform enables firms across the UAE to efficiently manage employee compliance and employee personal trading by providing a centralized, automated platform that streamlines pre-clearance, disclosure, and monitoring processes.
The system enables compliance teams to track employee trades in real-time, enforce blackout periods, flag potential conflicts of interest, and maintain comprehensive audit trails to meet regulatory requirements. With configurable workflows, automated approvals, and robust reporting capabilities, MCO helps firms stay aligned with SCA, DFSA, and VARA regulations, reduce operational risk, and promote a culture of accountability and transparency across their workforce.
Ready to see how MCO can help your financial services firm or bank effectively navigate complex regulations and compliance requirements across the UAE?
