In what circumstances may representatives of a broker or employees of brokerage firms trade for...

The DFM Professional Code of Conduct places tight controls on personal trading by broker representatives and brokerage-firm employees because such individuals may possess privileged knowledge of client orders, pending transactions or other market-sensitive information. The CISI UAE Financial Rules and Regulations states that representatives and other employees of brokerage firms may trade for their own accounts only through their own brokerage firms and after obtaining written approval from both the brokerage firm manager and the DFM . This arrangement enables the firm and market to supervise personal-account transactions and helps reduce the risks of front-running, misuse of confidential information and conflicts between employee interests and client interests. Trading through a spouse or family member does not provide a regulatory workaround; related-person transactions remain relevant to the restrictions. Likewise, dealing through another brokerage would defeat the transparency and supervisory purpose of the requirement. The rule requires DFM approval rather than approval merely from the Authority. Consequently, the combination stated in option C precisely reflects the CISI requirement.

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