Operational Resilience Under DFSA: Building Cyber-Resilient Financial Services in DIFC
Operational resilience has become a regulatory priority globally, and the DFSA is aligning with this trend. The concept goes beyond traditional business continuity planning to address a more fundamental question: can the firm continue to deliver critical services to customers and the market even when significant disruptions occur?
From Business Continuity to Operational Resilience
Traditional business continuity focuses on recovering from disruptions. Operational resilience focuses on preventing disruptions from affecting critical services in the first place, and managing the impact when they do. This shift has significant implications for cybersecurity. Rather than planning to restore systems after an attack, firms must design their technology architecture to absorb disruptions while maintaining service delivery.
Identifying Important Business Services
The starting point for operational resilience is identifying the firm's important business services. These are the services whose disruption would cause significant harm to customers, market integrity, or the firm's safety and soundness. For financial services firms in DIFC, important business services typically include client onboarding and account management, trade execution and settlement, payment processing, custody and safekeeping of client assets, and regulatory reporting.
Setting Impact Tolerances
For each important business service, firms must set impact tolerances that define the maximum tolerable disruption in terms of duration, data loss, and customer impact. These tolerances must be realistic, measurable, and approved by senior management. Impact tolerances drive the design of resilience controls including redundancy, failover capabilities, and data replication strategies.
Mapping Technology Dependencies
Firms must map the technology systems, data, and third-party services that each important business service depends on. This mapping reveals single points of failure, concentration risks, and dependencies that may not be immediately obvious. Understanding these dependencies is essential for designing effective resilience controls and for managing incidents when they occur.
Testing Resilience
Operational resilience must be tested regularly. This includes scenario-based testing that simulates realistic disruption scenarios including cyber attacks, technology failures, and third-party outages, recovery testing that verifies systems can be restored within impact tolerances, and communication testing that validates escalation and notification procedures work under pressure.
ITSEC Operational Resilience Services
ITSEC helps DIFC firms build operational resilience programs that satisfy DFSA expectations. From important business service identification through to scenario testing and resilience architecture review, we ensure firms can maintain critical services under pressure. Contact ITSEC for a resilience assessment.