Practice IV · DFSA & FSRA Regulatory

Cyber compliance for
DIFC & ADGM firms.

A dedicated practice for financial firms answering to the DFSA and FSRA — building the cyber risk management frameworks, evidence, and regulator dialogue that GEN 5.5 and GEN 3.5 expect, with working awareness of CBUAE, VARA, and the UAE IAR.

/ 01 — Landscape

Two free zones.
Rising expectations.

Cyber risk in the UAE's financial free zones has moved from IT concern to supervisory priority. Both regulators now expect a governed, documented, board-owned cyber risk management framework — and increasingly test for one.

DIFC · Dubai

DFSA — Cyber Risk Management (GEN 5.5)

The DFSA requires authorised firms to establish and maintain a cyber risk management framework proportionate to the nature, scale, and complexity of the business — covering governance, identification, protection, detection, response, and recovery, with senior management accountability and testing that produces evidence, not assumptions.

ADGM · Abu Dhabi

FSRA — Cyber Risk (GEN 3.5)

The FSRA's expectations run parallel: an established cyber risk framework, defined roles and escalation paths, incident response and recovery capability, and management information that lets the governing body actually supervise cyber risk rather than receive it as an annual slide.

The Wider Perimeter

CBUAE · VARA · UAE IAR

Many DIFC and ADGM firms also touch onshore and virtual-asset regimes: CBUAE expectations for payment and banking counterparties, VARA's technology and information requirements for virtual-asset firms, and the UAE Information Assurance Regulation for critical sectors. We keep engagements aware of the full perimeter, so one framework serves every supervisor who may ask.

/ 02 — Scope

What the practice
delivers.

01

Framework Build

A cyber risk management framework mapped clause-by-clause to GEN 5.5 or GEN 3.5 — proportionate to your firm, owned by named executives, and written to be operated.

02

Policy Suites

The policy and standards set beneath the framework — access, third parties, data, operations — coherent with each other and with what your firm actually does.

03

Incident Response Plans

IR plans with regulator notification obligations built into the timeline, executive playbooks, and tabletop exercises that produce documented lessons.

04

Business Continuity Alignment

Cyber scenarios integrated into BCP and recovery arrangements — so continuity plans survive contact with a ransomware event, not just a power cut.

05

Regulator Dialogue Support

Preparation for thematic reviews, supervisory meetings, and post-incident correspondence — the position assembled and rehearsed before the meeting, not during it.

06

Readiness & Annual Reviews

Point-in-time readiness assessments before authorisation or inspection, and annual framework reviews that keep documents aligned with a moving business.

/ 03 — Clients

Who the practice
serves.

Asset Managers

DIFC and ADGM investment firms where lean operating teams meet full supervisory expectations — and outsourced IT still needs governed oversight.

Fintechs

Innovation-licence and scaling fintechs moving from sandbox to full authorisation, where the cyber framework is part of the application itself.

Payments Firms

Money services and payments businesses balancing DFSA or FSRA obligations with PCI DSS scope and banking-partner due diligence.

Crypto & VARA Firms

Virtual-asset businesses navigating VARA's technology requirements alongside free-zone expectations — often under investor and exchange scrutiny at once.

/ 04 — Model

Advisory, structured
around your supervisor.

Engagements run either as a defined readiness project or as a standing retainer — commonly paired with our Fractional CISO practice, so the framework we build is also the framework someone senior continues to operate.

One boundary, stated plainly: we are an advisory practice — not a law firm, and not an external auditor. We build and strengthen your compliance position and stand beside you in regulator dialogue; formal legal opinions and statutory audits remain with your counsel and auditors, with whom we work readily.

01
Regulatory exposure review

Which rulebooks apply, what your licence category requires, and where your current arrangements stand against them.

02
Gap assessment & plan

A documented readiness assessment against GEN 5.5 / GEN 3.5, with a remediation plan sequenced around supervisory deadlines.

03
Build & embed

Framework, policies, IR plans, and continuity alignment built with your team — then exercised, so the paper matches practice.

04
Sustain

Annual reviews, board reporting, and standing support for regulator interactions — on a month-to-month retainer, scaled to your supervisory calendar.

/ 05 — Questions

Asked often.
Answered plainly.

We're mid-authorisation. Is it too early to build the framework?

It is exactly the right time. Authorisation reviews probe cyber and operational-risk arrangements, and retrofitting a framework after licensing is costlier than building it into the application. A proportionate framework, credibly documented, strengthens the submission itself.

Our IT is fully outsourced. Doesn't our provider handle this?

Your provider operates controls; the regulatory accountability stays with your firm and its governing body — outsourcing the function does not outsource the obligation. What supervisors look for is governed oversight: due diligence, contractual controls, monitoring, and management information. That oversight layer is precisely what we build.

Do you attend regulator meetings with us?

We prepare you for them, and where appropriate support you in them. The position, the evidence pack, and the answers to the difficult questions are assembled and rehearsed in advance. Your firm speaks for itself to its supervisor — our role is to make sure it speaks from strength.

How does this relate to ISO 27001 work we've already done?

It compounds. An ISO 27001-aligned ISMS covers much of what GEN 5.5 and GEN 3.5 expect; the regulatory work maps what exists, closes the free-zone-specific gaps — notification obligations, governance evidence, supervisory reporting — and presents it in the language your regulator reads. Nothing is rebuilt for its own sake.
/ 06 — Engage

Meet your regulator
from a position of strength.

A 30-minute call, including a first read on your DFSA or FSRA exposure. No obligation.

30 min · Video · No obligation