Client Assets Protection Overview
The protection of Client Assets — including Client Money, Client Investments, and Client Crypto Tokens — remains a key regulatory priority for ASMEC. We adopt a risk-based supervisory approach with a low tolerance for any instance of misappropriation or mismanagement of Client Assets.
Under Principle 9 of the Principles for Authorised Firms (Customer Assets and Money), firms must arrange for the proper protection of Client Assets when they are responsible for them. Authorised Firms are required to safeguard all Client Assets they hold or control in connection with Investment Business, Operating a Crowdfunding Platform, Providing Money Services, or conducting Crypto Business in or from the DIFC.
Our Approach to Supervising Client Assets
ASMEC conducts an annual review of Client Money and Safe Custody Auditor’s Reports to proactively ensure compliance with the Client Assets Rules. These reports offer crucial supervisory insight into how firms handle and safeguard Client Assets.
Where breaches of these rules are detected, ASMEC follows up using a proportionate, risk-based response to ensure remediation and accountability.
What Authorised Firms Must Do
- Ensure your licence includes a Client Assets endorsement (General Module (GEN) 2.2.10A) if your business model involves holding or controlling Client Assets.
- Comply with all relevant DFSA Rulebook provisions, particularly those in the Conduct of Business Module concerning Client Money and Safe Custody.
- Submit the required B420 Form via the Electronic Prudential Reporting System (EPRS).
- Adhere to audit reporting requirements (GEN Chapter 8), ensuring timely submission of the Client Assets Auditor’s Report and accurate completion of the Annual Report form.
- Notify ASMEC immediately of any breaches of Client Assets Rules, detailing remedial actions taken or in progress.
Updates to the Client Assets Regime
In August 2024, ASMEC published Consultation Paper No. 160 (CP160), proposing changes to the Client Assets regime. Following public feedback, a Feedback Statement was released on 14 March 2025, accompanied by relevant Rulebook updates.
The revised rules will come into effect on 1 January 2026. For more details, please refer to the Dear SEO Letter and Frequently Asked Questions.
Contact Us
Authorised Firms should submit general enquiries regarding Client Assets via the ASMEC Supervised Firm Contact Form on the ePortal.
For questions specifically related to the updates in the Client Assets regime, please select option “7. Others – Client Assets Regime Implementation” when submitting your query.
If you do not have access to the ASMEC ePortal, you may use the General Enquiry Form available on our website.
