Board Summary - Regional Uncertainties & Business Continuity

To our clients in DIFC, we would like to draw your attention there has been a communication from DFSA via SEO letter about the regional uncertainly and the need for business continuity. Please refer the information below for more details. 

Purpose

To brief the Board & senior management on the key regulatory expectations and required management actions arising from the DFSA Dear SEO Letters dated 01 March 2026 and 11 March 2026, issued in response to heightened regional and geopolitical uncertainties.

Regulatory Context

The DFSA is actively monitoring developments in the Middle East and their potential impact on financial markets, operational resilience, staff safety, and financial stability within the DIFC. Supervisory activities continue largely as normal, and firms should expect ongoing supervisory engagement.

Board and Senior Management Accountability

Boards and Senior Management remain fully accountable for maintaining effective governance, oversight, and escalation arrangements, ensuring timely and accurate management information, and preserving risk oversight notwithstanding remote, cross-border, or altered working arrangements.

Business Continuity and Crisis Management

Firms must maintain effective Business Continuity Plans, Disaster Recovery, and crisis management arrangements. Immediate notification to the DFSA is required where such arrangements are invoked or expected to be invoked, irrespective of whether a regulatory breach has occurred.

Mandatory DFSA Submission

All entities supervised by the DFSA, including Authorised Firms, Registered Auditors and registered DNFBPs, are required to submit the Business Continuity Measures Form via the DFSA ePortal by Friday, 13 March 2026, regardless of whether a Business Continuity Plan has been triggered.

Workforce and Operational Arrangements

Firms must promptly inform the DFSA of any material changes to staff working arrangements, including remote working, cross-border working, staff relocation, or evacuation that may affect operational resilience or the control environment.

Financial Resilience and Risk Monitoring

Boards should ensure enhanced monitoring of governance, operational resilience, cyber risk, capital, liquidity, and business-model-specific risks. Material deterioration, forward-looking risks, or threats to orderly operations must be escalated to the DFSA without delay.

Board Assurance Focus

The Board should seek assurance that business continuity arrangements are current and tested, DFSA escalation triggers are clear and operational, enhanced risk indicators are actively monitored, required submissions are completed on time, and engagement with the DFSA remains proactive and transparent.

Should you require any clarification or support please do not hesitate to reach out to us.