Category 3B is the DFSA specialist authorisation for custody and trustee services. It authorises two regulated activities: Providing Custody (safeguarding and administering investments belonging to a client) and Acting as the Trustee of a Fund (the role of independent fund trustee or depositary).
Cat 3B is held by specialist custodians (international tri-party custodians establishing a DIFC presence), by DIFC trust-and-fund-services firms, and in some structures by a fund manager's group affiliate where the manager wants in-house custody for its own funds.
Providing Custody.
Providing Custody is the regulated activity of safeguarding and administering investments belonging to a client. The defining features are segregation of client assets from the firm's own balance sheet, reconciliation, accurate record-keeping and the operational discipline to deliver client assets back on demand. The DFSA conduct rules around client-money and client-asset protection are central — the firm cannot use client assets for its own purposes, must maintain accurate records and must conduct regular reconciliations.
Acting as the Trustee of a Fund.
For a Public Fund domiciled in the DIFC, an independent fund trustee or depositary is mandatory. The trustee role includes oversight of the fund manager, custody of fund assets, NAV verification, investor-protection oversight and the trustee's reporting obligation to investors and the DFSA.
For DIFC Qualified Investor Funds and Exempt Funds, the trustee/depositary requirement is lighter — the manager has more latitude — but for the more structured product set the role remains common.
Capital under PIB.
Cat 3B capital under PIB is Base Capital plus Expenditure Based Capital plus, for substantial custody operations, an AUC-linked component reflecting the operational and counterparty risk associated with the assets the firm holds.
Approved Persons.
SEO, Finance Officer, Compliance Officer, MLRO mandatory. Risk Officer at scale. The Compliance Officer for a Cat 3B firm typically has specialist experience in client-asset segregation, custody operations and depositary frameworks because the DFSA examination tier here is custody-specific.
Cross-jurisdiction custody.
Most DIFC custodians operate through sub-custody networks reaching into global markets. The DFSA expects documented sub-custodian due diligence, ongoing monitoring, contractual rights to recover assets, and stress testing of the network in distress scenarios.
Conclusion.
Cat 3B is the specialist DIFC custody and depositary authorisation. For fund managers establishing in DIFC, the relationship with a Cat 3B custodian is one of the earliest decisions — it shapes the fund operational architecture and the public-fund pathway. Neo Legal supports both custodian licensees and fund managers selecting and contracting with custodians.
