Checklist: Technology & Compliance Requirements for DIFC / ADGM Firms

Why Technology & Compliance Drive Success in DIFC and ADGM

Setting up a regulated financial firm in DIFC (DFSA) or ADGM (FSRA) requires more than licensing approvals — it demands a fully operational technology, compliance, and governance stack before serving a single client.

Both regulators expect:

• Documented systems
• Automated controls
• Strong governance
• Clear audit trails
• Proper data handling
• Detailed reporting
• Ongoing monitoring

This article lays out a comprehensive, regulator-aligned checklist that new and existing firms can use to meet operational standards and avoid costly delays or inspection findings.

1. Core Regulatory Frameworks You Must Align With

1.1 DIFC / DFSA Rulebooks

• GEN (General Module) ‍
• COB (Conduct of Business) ‍
• AML (Anti-Money Laundering) ‍
• PIN (Prudential — capital) ‍
• ICL (Internal Controls) ‍
• Systems & Controls requirements

1.2 ADGM / FSRA Rulebooks

• GEN (General) ‍
• AML Rulebook ‍
• Prudential Framework (PRU) ‍
• Conduct of Business (COBS) ‍
• Fund Rules (FUNDS) ‍
• Technology & Cybersecurity Guidance

Both regulators emphasize technology, operational readiness, auditability, and automation.

2. Technology & Compliance Checklist

Below is the master checklist across nine essential categories.

2.1 Client Onboarding & KYC / AML

Both DFSA and FSRA require automated, documented onboarding workflows.

Mandatory Capabilities

• Client categorization (Retail / Professional / Market Counterparty)
• KYC / KYB onboarding
• AML checks (PEP, sanctions, adverse media)
• Suitability & appropriateness assessments
• Source of wealth / source of funds documentation
• Risk scoring & monitoring
• End-to-end audit trail
• Ongoing AML monitoring

Why it matters:

Onboarding failures are one of the most common causes of fines in GCC regulatory regimes.

2.2 CRM Purpose-Built for Regulated Firms

DFSA and FSRA expect firms to maintain comprehensive client records.

Required Features

• Client profile management
• Advisory logs
• Meeting & communication records
• Suitability assessments
• Client classification evidence
• Task management & workflow tracking
• Document history & audit logs

Generic CRMs (HubSpot, Salesforce, Monday) require heavy customization and often fail compliance tests.

2.3 Portfolio Management System (PMS)

For firms with “Managing Assets” or “Managing a Collective Investment Fund” licenses.

Minimum Requirements

• Multi-asset class support
• Multi-custodian integration
• Transaction, cash & position reconciliation
• Real-time valuations
• Corporate action processing
• Performance metrics (TWR/MWR)
• Risk metrics (VaR, exposures, concentration)
• Model portfolio support
• Fee engine (advisory, AUM, performance, watermarking)

Why it matters:

Poor or manual PMS processes trigger DFSA/FSRA issues during inspections and audits.

2.4 Client Reporting & Digital Client Portal

DFSA and FSRA demand clear, timely, and fair reporting.

Required Capabilities

• Performance reporting
• Portfolio positions & transactions
• Exposure & risk visualizations
• Trade confirmations (where applicable)
• Fee transparency
• Document delivery
• Secure encrypted portal access
• White-label branding

Clients expect modern, digital experience — especially HNWIs, UHNWIs, and family offices.

2.5 Multi-Custodian Data Aggregation & Reconciliation

Firms must consolidate data from:

• Global private banks
• Brokers
• Fund administrators
• Custody platforms

Checklist Requirements

• Automated data ingestion
• Normalization of multi-format feeds
• Transaction-level reconciliation
• Position reconciliation
• Cash reconciliation
• Error detection & exception handling

Manual reconciliation is no longer regulator-friendly.

2.6 Compliance Automation & Regulatory Reporting

DFSA and FSRA require robust systems to maintain ongoing compliance.

Core Capabilities

• AML transaction monitoring
• Compliance task automation
• Incident & breach registers
• Insider lists
• Conflicts of interest logs
• Best execution monitoring (if applicable)
• Complaints handling
• Risk assessment & scoring
• Internal audit workflows
• Regulatory returns preparation

Reporting Requirements

Depending on license:

• Financial reporting
• Capital adequacy reporting
• Suspicious transaction reporting
• Annual AML returns
• Fund reporting (for fund managers)
• Transaction reporting (if applicable)

Automation reduces regulatory risk significantly.

2.7 Document Management & Governance Records

Regulators require centralized, controlled documentation.

Required Elements

• Secure document vault
• Role-based permissions
• Policy versioning
• Board & investment committee minutes
• Outsourcing register
• Delegation of authority
• Cybersecurity policies
• BCP/DR documentation
• Employee training records

Regulators frequently request these documents during inspections.

2.8 Cybersecurity & IT Controls

DFSA and FSRA expect institutional-grade security.

Required Controls

• MFA (multi-factor authentication)
• Encrypted data protocols
• Access controls & user provisioning
• Penetration testing
• Incident response plan
• Regular vulnerability scanning
• Data loss prevention (DLP)
• Backup & recovery policies
• Secure APIs

Cyber weaknesses are a major cause of regulatory intervention.

2.9 Operational Workflows & Internal Systems

Firms must demonstrate fully operational business processes.

Checklist

1. Fee calculation workflows
2. Cash movement approvals
3. Trade approval logic
4. Investment committee process
5. Internal risk appetite statements
6. Delegated authority matrix
7. HR/employee compliance logs
8. Complaints process

Documentation + automation = operational readiness.

3. Why DIFC & ADGM Firms Choose Reluna

Reluna provides an integrated, regulator-aligned SaaS platform designed for DFSA- and FSRA-regulated firms.

Reluna includes:

• Full digital onboarding
• Client categorization engine
• AML / KYC workflows
• Investment management & PMS
• Multi-custodian aggregation
• Reconciliation automation
• DFSA- and FSRA-aligned CRM
• Client portal
• Document vault
• Compliance workflows
• Performance & exposure analytics
• Fee engine
• Full audit trail

Why this matters:

Most new firms in the UAE start with small teams — Reluna replaces 6–12 systems with one integrated platform, making regulatory compliance significantly easier.

4. Complete ADGM/DIFC Tech & Compliance Checklist (Summary)

• ‍Digital Onboarding
• ‍KYC / AML ‍
• Client Categorization ‍
• CRM ‍
• PMS ‍
• Reporting & Client Portal ‍
• Reconciliation Engine ‍
• Data Aggregation ‍
• Compliance Tools ‍
• Regulatory Reporting ‍
• Document Management ‍
• Cybersecurity Controls
• ‍Governance Records ‍
• Operational Workflow Automation

If a firm implements all these systems and controls, it is considered operationally ready by DFSA and FSRA standards.

5. Next Steps: Accelerate Your Operational Readiness

If you are launching a firm in DIFC or ADGM, or have recently received authorization, now is the ideal moment to implement your operational technology stack.

Reluna helps you:

• Achieve regulator-ready operational setup
• Launch onboarding workflows immediately
• Consolidate data and reporting
• Automate compliance
• Scale with confidence

👉 Request a Reluna demo to see how we support DIFC and ADGM firms end-to-end — from licensing to full-scale operations.