Personal Account Dealing Software Approve, Reconcile, Monitor and Record, Built for DIFC Firms
Custom personal account dealing software for DIFC authorised firms, built around the controls COB 6.2 of the DFSA Rulebook already expects - pre-trade approval, restricted and watch lists, broker-statement reconciliation, post-trade monitoring, and record-keeping with management information. Personal account dealing has been a standing conduct requirement since 2004; the work is making the controls real in a system rather than resting them on employee declarations and spreadsheets. This is employee conduct software, distinct from customer AML monitoring. We build the system; the compliance judgements and the regulatory relationship stay with your firm and its advisors.
Why PAD controls rest on a promise, not a process
Personal account dealing is a standing DFSA conduct requirement, yet in many firms the controls live in declarations, emails and spreadsheets. Approval is a verbal nod, the restricted list is a file someone updates by hand, the firm sees only what an employee chose to declare, and the record is scattered. Each control reads fine on paper and cannot be evidenced when a supervisor asks. The gap is not the policy, it is the machinery behind it.
Approval is a verbal nod
Pre-trade approval given by email or in passing, not checked against a current restricted list, so the firm cannot show each trade was cleared before it happened.
You see declarations, not accounts
Reliance on self-declaration without reconciling to broker statements means the firm sees what an employee reported, not the full account activity.
The restricted list drifts
A restricted and watch list kept in a spreadsheet and circulated by email drifts out of date and is hard to evidence as current at the moment of a given approval.
Monitoring is thin, records scattered
Post-trade monitoring done by occasional spot check, and records spread across email and files, are slow to assemble into the evidence a conduct supervisor expects.
The PAD controls, in one system
Four capability areas that turn personal account dealing from a set of declarations into a system that checks, reconciles, monitors and records, fitted to a DIFC firm and COB 6.2.
Pre-trade approval workflow
Employees request, the request is checked automatically against the current restricted and watch lists, an approver decides, and the whole chain is timestamped and kept, so approval is a process with an evidence trail.
Restricted and watch lists, versioned
The restricted and watch lists held in the system and versioned, with each approval bound to the list as it stood at that moment, so the firm can show what was restricted when a trade was cleared.
Holdings and broker reconciliation
Broker statements or feeds reconciled to declarations and approvals, flagging trades that were not approved or not declared, so the firm works from the account rather than the attestation.
Monitoring, record-keeping and MI
Post-trade monitoring for exceptions and conflicts, a full record kept by design, and the management information a board and a supervisor expect, with a defined escalation path.
A personal account dealing control that lives in a declaration is a promise. A control that lives in a system that checks, reconciles, monitors and records is a process. COB 6.2 has expected the process since 2004.
Every PAD control, evidenced.
A status view shows the personal account dealing controls. Policy, approval, restricted list, reconciliation, monitoring and the record each show their state, so coverage is visible rather than assumed.
Discuss your PAD controlsWhy DIFC firms invest in PAD software.
The standing rule, the supervisory signal, and the distinction that matters.
Talk to us about personal account dealing software.
A short call surfaces whether custom PAD software makes sense for your firm. Best positioned for DIFC authorised firms with real personal account dealing volume, several broker feeds to reconcile, or a restricted list that moves. A small firm with a simple book can run a disciplined manual process or a standard tool, and we will say so. We build the system that operationalises and evidences your controls; the compliance judgements and the obligations under the DFSA Rulebook remain your firm's, and you should take qualified advice on them. BY BANKS is an independent software engineering company: we design and build the platform and hand it over, your firm operates it. Regulator and rulebook names on this page are referenced descriptively to describe scope and interoperability, and imply no affiliation, endorsement, certification, or approval. This is not legal or compliance advice.
How personal account dealing software works for a DIFC firm
The detail behind the headline - from pre-trade approval and restricted lists, through broker reconciliation, to monitoring, record-keeping and MI. Anchored on COB 6.2, distinct from AML.
What changes, in practical terms
The page rests on the standing COB 6.2 obligation, not on any single supervisory publication. The rule has expected these controls for two decades; the work is making them real in a system.
The detailed questions DIFC firms ask us
Expand each to see how bespoke personal account dealing software actually works.
What does personal account dealing software actually cover?
Who this is for: DIFC authorised firms with real personal account dealing volume that want their controls in a system rather than in declarations. A small firm with a simple book may not need it, and we will say so.
Four connected capability areas: (1) Pre-trade approval workflow. (2) Restricted and watch lists, versioned. (3) Holdings and broker reconciliation. (4) Monitoring, record-keeping and MI. It operationalises and evidences the controls; it does not make the compliance judgements.
Is this different from AML transaction monitoring?
Yes, and the distinction matters. AML transaction monitoring watches your customers' transactions for money laundering, under the CBUAE framework. Personal account dealing software watches your employees' own trades for conduct and market-abuse risk, under the DFSA Rulebook.
Different subject, different regulator, different data and different system. A firm may run both, and they are built and scoped separately. This page is about employee personal account dealing, not customer AML.
Is personal account dealing a new requirement?
No. Personal account transactions have been governed by COB 6.2 of the DFSA Rulebook since 2004.
The DFSA's first Conduct Supervisory Pulse in June 2026 brought renewed supervisory attention to it, but the underlying obligation is long-standing. This software is built around that standing rule, which is why it is not tied to any single publication or date.
Is BY BANKS a compliance or regulated firm?
No. We are an independent software engineering company. We are not a compliance consultancy, a regulated or licensed firm, or a legal advisor, and we are not affiliated with or endorsed by the DFSA or the DIFC.
We do not advise your firm on its personal account dealing obligations or whether it meets them. We build the system that operationalises and evidences the controls your firm and its qualified advisors have decided it needs. For the obligations themselves, rely on the DFSA Rulebook and take qualified legal and compliance advice.
Does it replace our compliance team or surveillance vendor?
No. The system supports the compliance function, it does not replace it. The judgement on approvals, exceptions and escalations stays with compliance; the system carries the workflow, the reconciliation, the monitoring and the record.
Where a firm already runs a surveillance or compliance platform that works, the question is integration and fit rather than replacement, scoped before any build.
Do we need custom, or is off-the-shelf fine?
Often off-the-shelf is fine, and we will say so. A small firm with a handful of staff and a simple book can run a disciplined manual process or a standard tool.
The case for a fitted system strengthens with dealing volume, the number of broker feeds to reconcile, the need to evidence approvals against a moving restricted list, and the wish to own the data and the management information rather than rent them. Which side of that line your firm sits on is the first thing we work out.
What does this sit alongside in a typical DIFC firm stack?
Personal account dealing sits within the conduct and compliance layer.
Surveillance - it feeds approved and reconciled trades into wider conduct and market-abuse monitoring.
Broker and HR - it ingests broker statements or feeds and draws on the staff register for who is in scope. Integration approach is scoped during discovery, and we do not ask you to replace anything that works.
How long to go live, and what does it cost?
A scoping phase maps how personal account dealing runs today, the broker feeds in use, the restricted-list process, and the management information your board and supervisor expect. It produces a current-state map, gap analysis, recommended scope, integration scope and a fixed-price build proposal.
A core build runs from there, with the approval workflow and restricted list first and reconciliation, monitoring and MI after. Pricing varies by scope and the number of feeds, so a bracket is not published; scoping produces a fixed-price proposal with no obligation to proceed.
How each role experiences the change
Different roles feel personal account dealing differently. Custom software works when it reduces friction for each one.
Compliance Officer
Approvals checked against a live list and exceptions raised as cases, so oversight is evidenced not assumed.
Employees / Dealers
A clear request-and-approve workflow rather than chasing a sign-off by email.
Operations
Broker statements reconciled to declarations, so the picture is the account, not the attestation.
Board / SMF
Management information and a complete record on request, so the firm can answer a supervisor without a scramble.
Questions We Get Asked
Who is personal account dealing software for?
DIFC authorised firms with real personal account dealing volume that want their controls in a system rather than in declarations and spreadsheets. A small firm with a simple book may not need it, and we'll say so.
Is this different from AML transaction monitoring?
Yes. AML transaction monitoring watches your customers' transactions for money laundering under the CBUAE framework. Personal account dealing software watches your employees' own trades for conduct and market-abuse risk under the DFSA Rulebook. Different subject, regulator, data and system - a firm may run both, scoped separately.
Is personal account dealing a new requirement?
No. Personal account transactions have been governed by COB 6.2 of the DFSA Rulebook since 2004. The DFSA's first Conduct Supervisory Pulse in June 2026 renewed attention on it, but the obligation is long-standing, which is why this software is built around the standing rule rather than a single date.
Is BY BANKS a compliance or regulated firm?
No. We're an independent software engineering company, not a compliance consultancy, regulated firm or legal advisor, and not affiliated with the DFSA or DIFC. We don't advise on your obligations or whether you meet them - we build the system that operationalises and evidences the controls your firm and its advisors have decided it needs. Take qualified advice on the obligations themselves.
Does it replace our compliance team or surveillance vendor?
No. The system supports the compliance function, it doesn't replace it. The judgement on approvals, exceptions and escalations stays with compliance; the system carries the workflow, reconciliation, monitoring and record. Where a surveillance platform already works, the question is integration and fit, not replacement.
Do we need custom, or is off-the-shelf fine?
Often off-the-shelf is fine, and we'll say so. A small firm with a simple book can run a disciplined manual process or a standard tool. The case for a fitted system strengthens with dealing volume, the number of broker feeds to reconcile, evidencing approvals against a moving restricted list, and wanting to own the data and MI.
What does it cost and how long does it take?
A scoping phase produces a current-state map, gap analysis, recommended scope and a fixed-price build proposal. The approval workflow and restricted list come first, with reconciliation, monitoring and MI after. Pricing varies by scope and the number of feeds, so a bracket isn't published; scoping gives a fixed price with no obligation to proceed.
How does this connect to wider conduct surveillance?
Personal account dealing was Phase 1 of the DFSA's 2026 review of the trading environment, with further phases to follow. The same approve, reconcile, monitor, record and escalate discipline extends to best execution and market conduct, and the data feeds and case workflow a PAD system establishes feed the wider surveillance picture.
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