DFSA’s Thematic Review of High-Growth Firms in DIFC

The Riffle

The Dubai International Financial Centre (DIFC) continues its rise as a global financial hub, with the Dubai Financial Services Authority (DFSA) reporting remarkable growth across regulated firms. In 2025, the DFSA conducted a Thematic Review of High-Growth Firms, combining desk reviews, on-site visits, and supervisory engagement to understand growth drivers, assess operational resilience, and highlight good practices and areas for improvement .

The findings underline a central message: while growth in DIFC is strong, systems, controls, and governance must keep pace to ensure sustainable expansion.

Significant Growth in DIFC

Between 2021 and 2024, DIFC firms experienced substantial growth:

• +46% new authorised firms, bringing the total to over 900 regulated entities.

• $3.19 billion in net profit, with a 13% average annual growth rate.

• $172 billion in Assets Under Advisory (AUA) and $169 billion in Assets Under Management (AUM).

• 62,000 retail clients, growing at 72% annually.

• 9,000 employees, up 56% since 2021 .

This surge reflects DIFC’s consolidation as a global hub, powered by Dubai’s strategic location, modern legal framework, tax benefits, and investor migration.

Drivers of Growth

The review identified several growth catalysts:

• Dubai’s strategic location and Gulf Standard Time zone.

• A modern legal system and infrastructure.

• Influx of high-net-worth individuals and sovereign wealth fund activity.

• Rising interest in hedge funds, Islamic Finance, and commodities trading.

• Positive feedback on DFSA’s business-friendly but risk-based supervisory approach.

• Firms relocating operations and talent from London, Paris, and Singapore.

Key Themes from the Review

1. Business Strategy & Regulatory Business Plans (RBPs)

• Weaknesses: Outdated RBPs, lack of detail on expansion, and poor DFSA notifications.

• Good practice: Full RBP reviews, gap analyses, and early DFSA engagement.

• Action: Keep RBPs accurate, timely, and aligned with growth plans.

2. Governance & Decision-Making

• Weaknesses: Undefined strategies, rushed expansion, and high-level Board minutes lacking challenge.

• Good practice: New committees, revised Terms of Reference, and project-based licence upgrades.

• Action: Strengthen oversight, governance structures, and use management information (MI) to track growth.

3. Compliance & Risk

• Weaknesses: Insufficient compliance staff, reactive hiring, and limited involvement of Risk/Compliance in planning.

• Good practice: Risk taxonomies, incremental service rollouts, compliance embedded in business planning.

• Action: Scale compliance/risk resources with business size, evolve Compliance Monitoring Programmes, and engage risk officers early.

4. Staffing & Resourcing

• Weaknesses: Reactive recruitment, delaying hires until approvals.

• Good practice: Proactive hiring, insourcing Compliance/Finance/HR, skill gap analyses, and anticipating office space needs.

• Action: Continuously reassess staff adequacy and competencies.

5. Financial Resources

• Weaknesses: High cost-to-income ratios and margin pressures.

• Good practice: Diversified revenue, strong ICAAP/IRAP, stress testing, and Group support.

• Action: Keep financial resources aligned with growth, update capital/liquidity frameworks.

6. Client Onboarding

• Weaknesses: Control frameworks not always scaling with rapid client growth.

• Good practice: Quality assurance, AI-assisted onboarding, updated suitability assessments, and proactive offboarding.

• Action: Continuously enhance onboarding to meet AML/CTF obligations .

Conclusion

The DFSA’s review underscores a simple but vital truth: growth must be matched by governance, compliance, and risk management.

As DIFC cements its position as a global hub, firms must invest in robust systems, skilled staff, and strong oversight to ensure expansion is sustainable and trusted. The DFSA will continue its supervisory focus, expecting firms to address gaps identified in this review.

For high-growth firms in DIFC, the message is clear: strong governance is not a brake on growth — it’s the foundation for long-term success.

Read the full briefing document presented by 10 Leaves here -