DIFC Audit Requirements: Dubai International Financial Centre Guide

Operating in DIFC but confused about whether you need a DFSA-registered auditor versus a DIFC-registered auditor, and what specific regulatory reporting obligations apply to your entity? Dubai's premier financial free zone operates under the most sophisticated regulatory framework in the UAE, with distinct audit requirements for financial services firms versus commercial companies—and severe penalties for non-compliance with DFSA regulations.

With 37 years as both DIFC-registered and DFSA-approved auditors serving 28,000+ UAE businesses, Farahat & Co brings unparalleled expertise in navigating DIFC's dual regulatory environment. Our specialized team has conducted hundreds of audits for DFSA-regulated financial services firms, investment companies, and commercial entities, ensuring full compliance with both DIFC Companies Law and DFSA prudential standards. Explore our certified external audit services and DIFC location page.

This comprehensive DIFC audit guide explains:

• Critical distinction between DFSA-regulated entities (financial services) and non-regulated DIFC companies (commercial)
• DFSA-registered auditor requirements for financial services firms and why this matters
• DIFC-registered auditor requirements for commercial companies and size thresholds
• Regulatory reporting obligations: DFSA returns, capital adequacy verification, PIB/PIN submissions
• Enhanced corporate governance and audit committee requirements unique to DIFC
• Annual return filing procedures with DIFC Registrar and timing requirements
• Significant penalties for regulatory non-compliance (both DFSA and DIFC)

Whether you're a licensed financial services firm subject to DFSA oversight, an investment holding company, or a commercial trading entity in DIFC, this expert guide ensures you understand exactly which audit requirements apply to your specific structure and how to maintain full regulatory compliance.

DIFC Dual Regulatory Environment Explained

Understanding the Two Distinct Regimes

DIFC operates under TWO separate regulatory frameworks:

1. DFSA-Regulated Entities (Financial Services)

• Licensed financial services firms under Dubai Financial Services Authority
• Includes banks, investment firms, asset managers, insurance companies
• Subject to DFSA prudential rules and oversight
• Must use DFSA-registered auditors

2. Non-Regulated DIFC Companies (Commercial)

• General trading, holding companies, consulting, professional services
• Subject to DIFC Companies Law (not DFSA financial regulations)
• Must use DIFC-registered auditors (if audit required)

Common Confusion: Many business owners assume ALL DIFC companies need DFSA-registered auditors. This is FALSE. Only licensed financial services firms need DFSA-registered auditors. Commercial companies use DIFC-registered auditors.

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DFSA-Regulated Entities: Financial Services Audit Requirements

Who is DFSA-Regulated?

Licensed Financial Services Activities:

Banking & Credit:

• Accepting deposits
• Providing credit
• Operating money/value transfer services

Investment Services:

• Dealing in investments as principal or agent
• Arranging deals in investments
• Managing assets
• Advising on financial products

Fund Management:

• Operating a collective investment fund
• Managing a profit-sharing investment account
• Providing fund administration services

Insurance:

• Effecting or carrying out contracts of insurance
• Insurance intermediation
• Managing insurance funds

Not DFSA-Regulated (Even if in DIFC):

• Holding companies (unless managing funds)
• Trading companies
• Consulting/professional services
• Technology companies
• Family offices (unless providing regulated services)

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DFSA-Registered Auditor Requirements

Mandatory Qualifications for DFSA Auditors:

1. DFSA Registration:

• Auditor must be registered with DFSA as Registered Auditor
• Separate registration from general UAE MOE approval
• DFSA maintains published list of registered audit firms

2. International Membership:

• Must be member of recognized international accounting body
• ACCA, ICAEW, CPA Australia, etc.
• Partner signing audit report must hold qualifying membership

3. Professional Indemnity Insurance:

• Minimum coverage: USD 5 million per claim
• Aggregate coverage requirements vary by audit firm size
• Annual renewal required

4. DFSA Compliance:

• Subject to DFSA oversight and inspections
• Quality control reviews by DFSA
• Continuing professional education requirements

How to Verify DFSA Auditor Registration:

Method 1: DFSA Public Register

• Visit: www.dfsa.ae
• Navigate to "Public Registers" → "Registered Auditors"
• Search by firm name
• Verify current registration status

Method 2: Request Documentation Ask prospective auditor for:

• DFSA Registered Auditor certificate (current year)
• Professional indemnity insurance certificate
• List of recent DFSA-regulated clients (redacted)
• DFSA inspection reports (if willing to share)

Method 3: Contact DFSA Directly

• Email: supervision@dfsa.ae
• Confirm auditor's registration status
• 2-3 business day response typical

Red Flags - Non-DFSA Auditors:

⚠️ Warning Signs:

• Claims to be "DIFC-registered" but not "DFSA-registered" (for financial services, you need DFSA!)
• Cannot produce current DFSA registration certificate
• Significantly lower fees than market (may lack DFSA expertise)
• Not familiar with DFSA reporting requirements (PIB, PIN, etc.)

Consequence of Using Non-DFSA Auditor:

• DFSA will REJECT audit report
• Must redo entire audit with DFSA-registered firm (double cost!)
• Regulatory penalties for late filing: AED 10K-50K+
• License suspension risk
• Senior management accountability (may face DFSA enforcement)

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DFSA Regulatory Reporting Requirements

Financial Services Firms Must Submit:

1. Audited Financial Statements

• Full IFRS financial statements
• Within 4 months of financial year-end
• Filed electronically through DFSA portal

2. Prudential Returns (PIB/PIN)

• PIB (Prudential Information Bulletin): Quarterly and annual
• PIN (Prudential Investment Business): Quarterly and annual
• Capital adequacy ratios
• Liquidity metrics
• Risk concentration data

3. Regulatory Capital Verification

• Auditor must verify regulatory capital calculations
• Compliance with minimum capital requirements
• Capital adequacy assessment

4. Client Money Audit Report (if applicable)

• Separate audit of client money arrangements
• CASS (Client Asset Sourcebook) compliance
• Segregation verification

5. AML Compliance Report (for certain firms)

• Anti-Money Laundering controls assessment
• Auditor's opinion on AML framework
• Required for banks, money service businesses

Deadlines & Penalties:

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Severe Non-Compliance:

• License suspension
• Senior management prohibition orders
• Enforcement action and public censure
• Withdrawal of DFSA license

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Non-Regulated DIFC Companies: Commercial Audit Requirements

Size-Based Audit Thresholds

Audit Mandatory If Company Meets TWO of THREE Criteria:

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Examples:

Company A: Mandatory Audit

• Revenue: AED 15M
• Assets: AED 4M
• Employees: 12
• Result: Meets 1 criteria (revenue) → NO mandatory audit

Company B: Mandatory Audit

• Revenue: AED 14M
• Assets: AED 7M
• Employees: 35
• Result: Meets 2 criteria (revenue + assets) → YES mandatory audit

Company C: Mandatory Audit

• Revenue: AED 8M
• Assets: AED 7.5M
• Employees: 60
• Result: Meets 2 criteria (assets + employees) → YES mandatory audit

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DIFC-Registered Auditor Requirements (Non-Regulated)

Qualifications for DIFC Auditors:

1. DIFC Registration:

• Registered with DIFC Registrar of Companies
• Separate from DFSA registration (for commercial companies)

2. UAE Ministry of Economy Approval:

• Must hold current MOE auditor license
• Certificate number appears on audit report

3. Professional Qualifications:

• CPA, ACCA, CA, or equivalent
• Minimum 5 years audit experience

How to Verify DIFC Auditor Registration:

Method 1: DIFC Registrar

• Email: roc@difc.ae
• Request confirmation of auditor's DIFC registration
• 1-2 business day response

Method 2: Request Documentation

• DIFC registration certificate
• MOE auditor approval
• Professional indemnity insurance

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DIFC Commercial Company Filing Requirements

Annual Return Filing:

Deadline: Within 4 months of financial year-end

What to File:

• Annual return form (via DIFC portal)
• Audited financial statements (if threshold met)
• OR Management accounts (if below threshold)
• Beneficial ownership declaration (UBO)
• Board resolutions

Filing Fee: AED 1,500-3,000 (based on company type)

Late Filing Penalties:

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Real-World DIFC Audit Case Studies

Case Study 1: Asset Management Firm - DFSA Regulatory Audit Success

Company Profile:

• Industry: Asset management (DFSA-licensed)
• Assets Under Management: USD 180M
• Employees: 22
• Year-End: December 31, 2024
• DFSA Category: Category 4 (Investment Management)

Regulatory Requirements:

• Audited financial statements (IFRS)
• Annual PIB return (prudential capital)
• Client money audit report (AED 45M client assets)
• Minimum capital: AED 500K

Audit Scope:

1. Financial Statement Audit:

• Revenue: AED 12.5M (management fees)
• Expenses: AED 9.8M
• Regulatory capital: AED 2.1M (well above minimum)

2. Prudential Capital Verification:

• Base capital requirement: AED 500K
• Expenditure-based capital: AED 2.45M (25% of annual expenses)
• Required capital: AED 2.45M (higher of two)
• Actual capital: AED 2.1M
• Shortfall identified: AED 350K

Challenge Discovered: During audit, capital calculation revealed shortfall due to:

• Increased operational expenses (expanded team)
• Expenditure-based requirement increased
• Management unaware of higher requirement

Resolution:

Week 1 (Feb 1-7):

• Auditor identified capital shortfall during fieldwork
• Immediately notified senior management
• Calculated exact amount needed: AED 350K

Week 2 (Feb 8-14):

• Emergency board meeting convened
• Shareholder agreed to capital injection
• AED 400K transferred (AED 50K buffer)

Week 3 (Feb 15-21):

• Capital injection confirmed and verified
• Recalculated prudential capital: AED 2.5M (compliant!)
• Clean audit opinion issued

Week 4 (Feb 22-28):

• Filed audited financials with DFSA (on time)
• Filed PIB return showing compliant capital
• Filed client money report (no findings)

Results:

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What If Shortfall Not Identified:

• File PIB showing non-compliance
• DFSA enforcement action (AED 50K-200K fine)
• Potential license restriction
• Reputational damage

CEO Quote: "Our auditor's early identification of the capital shortfall saved us from regulatory enforcement. We had time to fix it before filing. The AED 65K audit fee prevented a potential AED 200K DFSA fine!"

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Case Study 2: Holding Company - Commercial DIFC Audit (First-Time)

Company Profile:

• Industry: Investment holding company (non-regulated)
• Assets: AED 85M (investments in subsidiaries)
• Revenue: AED 2.5M (dividend income, management fees)
• Employees: 8
• Year-End: March 31, 2024
• First year subject to mandatory audit

Threshold Analysis:

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Result: Meets 1 of 3 criteria → NO mandatory audit required

However: Company voluntarily chose to audit because:

• Major banking relationships require audited financials
• Preparing for potential investor entry (private equity)
• Good governance practice for AED 85M asset base
• Tax planning (UAE corporate tax transparency)

Audit Findings & Adjustments:

Issue 1: Investment Valuation (IAS 28)

• Subsidiary investments recorded at historical cost: AED 45M
• Fair value (based on net assets): AED 52M
• Recommended: Equity method accounting for associates
• Adjustment: Reclassified as equity-accounted investments, recognized share of profits

Issue 2: Dividend Income Recognition (IAS 18)

• Recognized dividends when declared by subsidiaries
• IFRS: Recognize when right to receive is established
• Adjustment: AED 850K dividend accrued (declared Dec but received April)

Issue 3: Related Party Disclosures (IAS 24)

• Extensive related party transactions (management fees, loans)
• Initial disclosure: Incomplete (only amounts, no terms)
• Enhancement: Added detailed notes showing:
  • Transaction nature
  • Terms comparison to third parties
  • Outstanding balances
  • Guarantees provided

Issue 4: Consolidated vs. Separate Statements

• Initially prepared separate company statements only
• Auditor recommended: Consolidated group statements
• Outcome: Prepared both (separate for DIFC filing, consolidated for stakeholders)

Results:

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Unexpected Benefit: 6 months later, private equity firm approached for investment. Having audited consolidated financials significantly accelerated due diligence. Deal closed 40% faster than comparable transactions.

CFO Quote: "We almost skipped the audit since we were below the threshold. Best decision we made! The audit identified AED 8M in valuation issues and the consolidated statements helped us close our PE deal months faster."

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Case Study 3: Professional Services Firm - Narrowly Avoided Penalty

Company Profile:

• Industry: Management consulting (DIFC commercial)
• Revenue: AED 13.5M
• Assets: AED 4.2M
• Employees: 48
• Year-End: December 31, 2024
• DIFC Filing Deadline: April 30, 2025

Threshold Analysis:

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Result: Meets 1 of 3 criteria → NO mandatory audit required

However: Company INCORRECTLY assumed audit was mandatory (thought "revenue > 12M" alone triggered audit). Engaged auditor in January, wasting AED 35K on unnecessary audit.

Discovery: Mid-audit (late March), auditor informed company:

• "You don't actually need this audit based on thresholds"
• Only 1 criterion met (need 2 of 3)
• Could file management accounts instead

Company's Decision:

• Already AED 25K spent on audit (50% complete)
• Decided to complete audit anyway because:
  • Bank required audited financials for AED 2M facility renewal
  • Tender for major government contract specified audited financials
  • Only AED 10K more to complete (vs. AED 25K already spent)

Outcome: Completing audit proved valuable:

• Bank renewed facility based on clean audit (would have been difficult with unaudited)
• Won government tender (AED 4.5M contract) requiring audited financials
• Audit identified AED 180K unclaimed VAT input (recoverable!)

ROI on "Unnecessary" Audit:

• Cost: AED 35,000
• VAT recovered: AED 180,000
• Contract won (requiring audit): AED 4.5M (AED 680K profit)
• Net benefit: AED 825K+

Managing Partner Quote: "We thought we were legally required to audit. Turns out we weren't—but completing it anyway was the best business decision. The ROI was 2,357%!"

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DIFC vs Other Free Zones: Audit Comparison

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Key Observations:

DIFC Financial Services:

• Highest regulatory standards in UAE
• Most expensive audits (regulatory complexity)
• Strictest enforcement
• Best for firms needing international financial services credibility

DIFC Commercial:

• Favorable size thresholds (many SMEs exempt from mandatory audit)
• Enhanced governance expectations
• Premium jurisdiction for regional headquarters
• Higher costs than DMCC/JAFZA

When to Choose DIFC:

• Financial services requiring DFSA license
• International investor/stakeholder base
• Need common law jurisdiction (vs. civil law mainland)
• Asset management, fintech, financial advisory

When to Choose Other Zones:

• DMCC: Commodity trading, straightforward audit needs
• JAFZA: Logistics, large-scale operations, flexible thresholds
• Dubai South: Aviation, logistics near Al Maktoum Airport

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DIFC Audit Costs: Detailed Breakdown

DFSA-Regulated Entities (Financial Services)

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Additional Services (Often Required):

• Client money audit: +AED 15K-35K
• Regulatory capital verification: +AED 10K-25K
• AML compliance report: +AED 20K-40K

Total Package: AED 90K-500K depending on complexity

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DIFC Commercial Companies (Non-Regulated)

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Factors Increasing Cost (+30-60%):

• Group consolidation (multiple entities)
• Complex investment structures
• First-time IFRS adoption
• Tight deadlines (< 60 days to filing)

Factors Reducing Cost (-15-25%):

• Simple holding structure
• Well-organized records
• Multi-year engagement
• Early auditor engagement (90+ days before deadline)

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Frequently Asked Questions

1. I have a DIFC holding company. Do I need a DFSA-registered or DIFC-registered auditor?

DIFC-registered auditor (NOT DFSA-registered).

Key Distinction:

DFSA-Registered Auditors:

• ONLY for licensed financial services firms
• Firms with DFSA license (Category 1-4)
• Banks, asset managers, insurance companies
• Must comply with DFSA prudential rules

DIFC-Registered Auditors:

• For non-regulated DIFC companies
• Holding companies, trading, consulting, services
• Subject to DIFC Companies Law (not DFSA)

Your Holding Company: Unless you're operating a licensed fund or providing regulated investment management services, you are a NON-REGULATED DIFC company:

• Use DIFC-registered + MOE-approved auditor
• File annual return with DIFC Registrar (not DFSA)
• No PIB/PIN returns required
• Lower audit costs (AED 35K-60K vs. AED 80K-150K for DFSA)

Exception: If your holding company is the holding company OF a DFSA-licensed entity, check with DFSA whether group audit required. Usually only the licensed entity needs DFSA audit.

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2. My DIFC company has revenue AED 13M, assets AED 5M, 45 employees. Do I need audit?

No mandatory audit required (but voluntary audit highly recommended).

Threshold Check:

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Result: 1 of 3 criteria met → NO mandatory audit

You can file management accounts (unaudited) with DIFC Registrar.

However, Consider Voluntary Audit If:

Banking Relationships:

• Applying for credit facilities > AED 500K
• Trade finance (L/C, guarantees)
• International banking relationships

Business Development:

• Participating in tenders (government or large corporate)
• Investor due diligence (PE, VC, strategic)
• Franchise or partnership agreements

Internal Benefits:

• Financial reporting improvement
• Identify errors/leakage
• IFRS compliance (for tax purposes)
• Management visibility

Voluntary Audit Cost: AED 30K-40K typical Potential Benefits: Access to banking, tenders worth AED millions

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3. Can I change from DFSA-registered auditor to cheaper DIFC-registered auditor to save costs?

ONLY if your company is non-regulated. If you're DFSA-licensed, you MUST use DFSA-registered auditor.

Scenario A: DFSA-Licensed Financial Services Firm

Answer: NO, you cannot switch.

If you hold DFSA license (Category 1-4):

• MUST use DFSA-registered auditor (regulatory requirement)
• No exceptions
• Switching to non-DFSA auditor = non-compliance
• Penalties: AED 50K-200K+ enforcement action
• License suspension risk

Cost Reality: DFSA audits are expensive (AED 60K-300K) because:

• Regulatory complexity (PIB/PIN, capital calculations)
• Client money verification
• Higher professional indemnity insurance costs
• DFSA oversight and quality requirements

Our Recommendation: Don't try to cut costs by using cheaper non-DFSA auditor. Instead:

• Improve record-keeping (reduce audit hours)
• Engage auditor early (avoid rush premium)
• Multi-year engagement (negotiate better rate from year 2)
• Consider mid-tier DFSA auditor (vs. Big 4) if appropriate

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Scenario B: Non-Regulated DIFC Company (Mistakenly Using DFSA Auditor)

Answer: YES, you can (and should) switch to save costs.

If you're a holding company, trading company, or other non-regulated entity:

• You DON'T need DFSA-registered auditor
• DIFC-registered + MOE-approved auditor is sufficient
• Potential savings: 30-50% on audit fees

Example:

• Current audit fee (DFSA auditor): AED 85,000
• Appropriate audit fee (DIFC auditor): AED 50,000
• Annual savings: AED 35,000

Why You May Be Overpaying: Some companies mistakenly engage Big 4 DFSA-registered firms for non-regulated entities. Unless you need Big 4 brand for stakeholders, mid-tier DIFC-registered firms provide excellent service at lower cost.

Switching Process:

1. Confirm you're non-regulated (check DFSA public register)
2. Verify DIFC size thresholds (do you even need audit?)
3. Engage DIFC-registered + MOE-approved auditor
4. Complete year 1 audit (slightly higher due to transition)
5. Save 30-50% from year 2 onwards

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4. What happens if I miss the 4-month DIFC filing deadline?

Penalties, license issues, and potential personal liability for directors.

Late Filing Consequences:

Immediate Financial Penalties:

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License Impact:

• License renewal blocked
• Cannot amend license (add activities, change shareholders)
• Cannot apply for new visas
• Cannot renew employee visas
• Banking relationships may be affected

Director/Officer Liability:

• DIFC Companies Law: Directors responsible for compliance
• Personal fines: Up to AED 50,000 per director
• Potential director disqualification for repeated non-compliance
• Criminal liability in severe cases (rare but possible)

DFSA-Regulated Additional Consequences:

• Senior management accountability
• Restriction on authorized individuals
• Prohibition orders (cannot work in DFSA-regulated firms)
• Public censure (published on DFSA website)
• License withdrawal (extreme cases)

Recovery Process:

If You're Late:

Step 1: Immediate Action (Day 1)

• Engage auditor for express/emergency audit service
• Contact DIFC ROC/DFSA to notify of delay
• Provide explanation and expected filing date

Step 2: Expedite Audit (Days 2-14)

• Dedicate internal resources to support audit
• Respond to auditor requests same-day
• Work overtime/weekends if needed
• Pay for express audit service

Step 3: File ASAP (Day 15)

• Submit as soon as audit complete
• Include explanation letter
• Pay penalty immediately
• Request waiver (low success rate but worth trying)

Step 4: Implement Controls

• Set calendar reminders 120 days before deadline
• Engage auditor 90 days before year-end
• Monthly bookkeeping (not year-end catch-up)

Penalty Waiver Possible?

Success Rate: < 5% for DIFC commercial, < 1% for DFSA

Valid Reasons (May Be Considered):

• Auditor sudden resignation/death (documented)
• Force majeure (natural disaster, government mandate)
• DIFC portal technical failure (documented complaints)
• Serious illness of key personnel (medical certificates)

Invalid Reasons (Will Be Rejected):

• "We forgot"
• "We were busy"
• "We didn't know about the deadline"
• "Auditor was slow" (unless auditor issue is documented)

Our Strong Recommendation: Build 30-day buffer. If deadline is April 30, target completion by March 31. Unexpected delays (auditor queries, missing documents, UAE public holidays) can consume weeks.

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5. Do DIFC companies need to prepare for UAE Corporate Tax?

Yes! DIFC companies are subject to UAE Corporate Tax effective June 1, 2023.

Corporate Tax Basics for DIFC:

Tax Rate:

• Standard rate: 9% on taxable income
• Free zone qualifying income: 0% (if conditions met)
• Non-qualifying income: 9%

Qualifying Income Conditions (0% Tax):

Must meet ALL requirements: DIFC company registered in free zone Maintains adequate substance in UAE (office, employees) Derives qualifying income (specific business activities) Earns income from qualifying transactions Does NOT elect standard 9% tax treatment Complies with all regulatory requirements

Non-Qualifying Income (9% Tax):

• Income from UAE mainland (domestic transactions)
• Income from non-qualifying activities
• Excluded activities (banking, certain services)

DFSA-Regulated Entities: Most financial services are qualifying activities IF:

• Licensed by DFSA
• Conducted from DIFC premises
• Adequate substance maintained

Impact on Audit:

New Audit Requirements:

1. Deferred Tax Accounting (IAS 12)

• Calculate temporary differences
• Recognize deferred tax assets/liabilities
• Impact on financial statements from 2024 onwards

2. Transfer Pricing Documentation

• Related party transactions must be arm's length
• Documentation required for transactions > AED 200K
• Auditor will review pricing policies

3. Separate Qualifying vs. Non-Qualifying Income

• Track income by source
• Maintain clear records
• Auditor may need to verify allocation

Cost Impact:

• Audit fees may increase 10-20% for tax work
• Separate tax return preparation: AED 8K-25K
• Transfer pricing documentation: AED 15K-40K (if needed)

Recommendation:

• Engage tax advisor alongside auditor
• Understand qualifying income rules for your activities
• Prepare tax provision in monthly financials (don't wait for audit)
• Budget additional AED 20K-50K for tax compliance costs

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Conclusion

DIFC's dual regulatory framework—DFSA for financial services and DIFC Companies Law for commercial entities—creates distinct audit requirements that business owners must understand to ensure compliance and optimize costs. Success in DIFC requires identifying which regime applies to your entity, engaging the appropriate registered auditor (DFSA-registered for financial services, DIFC-registered for commercial), maintaining full IFRS-compliant financials, and filing within the strict 4-month deadline to avoid significant penalties.

Your DIFC Audit Success Formula:

Identify your regime (DFSA-regulated vs. DIFC commercial) Verify auditor registration (DFSA or DIFC as appropriate—critical!) Understand size thresholds (2 of 3 criteria for commercial companies) Engage auditor early (90 days before year-end minimum) Prepare for regulatory reporting (PIB/PIN if DFSA-regulated) File 30+ days before 4-month deadline (avoid AED 5K-50K penalties) Budget appropriately (AED 35K-300K+ depending on type) Prepare for corporate tax (deferred tax, transfer pricing from 2024)

At Farahat & Co, we're both DIFC-registered and DFSA-registered auditors with:

• 37 years UAE audit experience including DIFC since inception
• Dual registration (serve both financial services and commercial entities)
• Deep expertise in DFSA prudential reporting (PIB/PIN, client money)
• 200+ DIFC audits completed (asset managers, holding companies, consultancies)
• Fixed-fee pricing with transparent scope
• Electronic filing support (DFSA portal and DIFC ROC)
• Corporate tax advisory integrated with audit service

Ready for your DIFC audit? Contact us today for a free consultation. Our team will identify which registration regime applies to your entity, provide competitive quote appropriate to your needs, and ensure seamless compliance with DIFC/DFSA requirements.

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