The DFSA’s 2025 Thematic Review: Strengthening Whistleblowing Frameworks.

Promoting Transparency and Integrity in Financial Institutions

In January 2025, the Dubai Financial Services Authority (DFSA) released its Whistleblowing Thematic Review, a significant milestone in fostering ethical behaviour and regulatory compliance within financial institutions operating in or from the Dubai International Financial Centre (DIFC). The review highlights the critical role whistleblowing plays in promoting transparency, mitigating risks, and safeguarding the operational integrity of regulated entities.

Key Themes from the Review

The DFSA conducted its review through surveys, desk-based assessments, and onsite visits to a diverse sample of regulated entities. Below are the main findings:

1. Whistleblower Protection

Protecting whistleblowers’ confidentiality and shielding them from retaliation are fundamental aspects of the DFSA’s whistleblowing framework. While 97% of respondents reported measures to ensure anonymity, many lacked systems to monitor whistleblowers’ treatment after raising concerns.

Action Required: Entities must strengthen protections by implementing mechanisms to monitor whistleblowers’ experiences over time, ensuring they are not subjected to any form of detriment.

2. Policies and Procedures

Clear and effective whistleblowing policies are essential for enabling the secure reporting and escalation of regulatory concerns. However, 47% of reviewed entities exhibited deficiencies, such as poor documentation or inadequate processes for handling concerns.

Good Practices: Leading firms adopt country-specific policies that integrate local regulatory requirements with global standards, ensuring a more robust whistleblowing framework.

3. Governance and Oversight

Effective whistleblowing governance requires robust oversight by governing bodies or senior management. Yet, 47% of entities lacked structured systems to monitor and track whistleblowing reports.

Action Required: Regulated entities must ensure their governing bodies receive regular updates on whistleblowing cases, including trends, resolutions, and key learnings.

4. Training and Awareness

Raising awareness about whistleblowing arrangements is essential to fostering a culture of transparency. While 88% of respondents provide training, many fail to effectively communicate reporting mechanisms and protections.

Good Practices: Regular awareness campaigns, tailored training sessions, and employee feedback mechanisms, such as surveys, are effective in building a strong ‘speak-up’ culture.

5. Reporting Channels

Accessible and secure reporting mechanisms are vital. Although most entities provide internal reporting channels, only 39% extend these to third parties, such as ex-employees or service providers.

Action Required: Entities must expand reporting channels to third parties and ensure employees are aware of alternative reporting options, such as contacting the DFSA directly.

How j. awan & partners Can Support Your Whistleblowing Framework

At j. awan & partners, we specialise in assisting financial institutions to implement and enhance whistleblowing frameworks in line with DFSA requirements. Our services include:

• Policy Development: Designing comprehensive whistleblowing policies tailored to your organisation’s needs and regulatory obligations.

  
  

• Governance Reviews: Strengthening whistleblowing governance structures and ensuring robust oversight mechanisms.

  
  

• Training and Awareness Programmes: Educating employees on how to report concerns and understand their protections under the whistleblowing framework.

  
  

• Monitoring and Testing: Evaluating the effectiveness of your whistleblowing arrangements through compliance audits and independent reviews.

Why It Matters

Effective whistleblowing frameworks go beyond regulatory compliance; they are a cornerstone of ethical governance and organisational integrity. By fostering a culture of transparency, firms can not only meet regulatory expectations but also enhance trust among stakeholders and mitigate operational risks.

Contact Us for Expert Guidance

As the regulatory environment evolves, staying ahead of compliance requirements is essential. At j. awan & partners, we are committed to helping firms build robust whistleblowing frameworks that align with DFSA standards.

Contact us at info@jawanpartners.com to learn more about how we can support your organisation in strengthening its compliance and governance practices.