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ARTICLE · 10 MAY 2017

DIFC: Severe Restriction for DIFC Enforcement

Fenwick Elliott LLP
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Jurisdiction in Dubai comprises the local United Arab Emirates (UAE) or "local" courts and the Dubai International Financial Centre (DIFC) court or the "offshore" court. One of the principal differences between the two jurisdictions is the legal system.

United Arab EmiratesReal Estate and Construction
Nicholas Gould
Nicholas Gould
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Co-authored by Tatyana Tall, Partner and Paralegal, Fenwick Elliott

The Dubai International Financial Centre

Jurisdiction in Dubai comprises the local United Arab Emirates (UAE) or "local" courts and the Dubai International Financial Centre (DIFC) court or the "offshore" court. One of the principal differences between the two jurisdictions is the legal system. The local UAE courts use the civil law and its main arbitral institutions are the Dubai International Arbitration Centre (DIAC) and the Abu Dhabi Commercial Conciliation and Arbitration Centre (ADCCAC). In contrast, DIFC has a common law system, and the DIFC–LCIA Arbitration Centre.  The DIFC Arbitration Law 2008 is based on the UNCITRAL Model on International Commercial Arbitration and has been referred to as a "Common Law island floating in a Civil Law sea".1

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