Thematic Review: Conflicts of Interest

A Dear SEO Letter went to 710 DIFC firms in February 2025 and 97 per cent responded, followed by a phase two sample of 25 firms. Three quarters of respondents reported identifying no conflicts of interest at all in the preceding 24 months, with the distribution running 507 firms reporting none, 137 reporting between zero and five, 11 reporting six to ten and 31 reporting more than ten. The regulator's finding is that there was "a general lack of discussion or challenge at the Board or Governing Body level on risks related to conflicts of interest", and that firms with years of nil returns could not demonstrate that the absence had ever been questioned by the governing body.