Dubai processes more than AED 1.5 trillion in non-oil trade annually. The city is headquarters to regional operations for thousands of multinational companies, a free zone ecosystem that hosts more than 50,000 registered businesses, and a financial centre — the DIFC — that operates its own English-language common-law court system independent of the UAE's civil law judiciary.
For creditors, Dubai presents a paradox: the city's commercial infrastructure is world-class, but its enforcement landscape requires navigating between two distinct legal systems, understanding cultural negotiation dynamics that differ fundamentally from Western commercial norms, and recognising that the debtor's public visibility in Dubai's business community is often a more powerful collection tool than any court order.
The dual court system
Dubai operates two parallel court systems, and choosing the wrong one can add six months to your recovery timeline.
The DIFC Courts operate under common law principles, with proceedings conducted in English and judgments that are internationally recognisable. If your contract contains a DIFC jurisdiction clause, or if the debtor is registered in the DIFC, these courts offer familiar procedure, experienced commercial judges, and a small claims tribunal that handles claims up to AED 500,000 (approximately $136,000) with streamlined process.
The Dubai Courts (local judiciary) operate under UAE civil law, with proceedings conducted in Arabic. All foreign-language documents must be translated by a certified Arabic translator and attested. The process is more formal and typically slower, but the Dubai Courts have exclusive jurisdiction over most enforcement actions against assets located outside the DIFC.
The critical question for creditors is not which system is "better" — it's which system has jurisdiction over your debtor's assets. A DIFC judgment against a debtor whose bank accounts, property, and business operations are all in mainland Dubai requires a recognition proceeding through the Dubai Courts before enforcement can begin. This process has been streamlined through the Judicial Authority Law, but it still adds procedural steps.
Our Dubai team assesses jurisdiction and asset location before filing any action. The assessment determines the optimal court, the enforcement pathway, and the realistic timeline — information that prevents creditors from filing in the wrong system and discovering the error months later.
The cultural enforcement layer
Dubai's business community is smaller and more interconnected than its skyline suggests. Reputation travels fast. A debtor who is known to have outstanding creditor claims faces consequences that extend beyond legal enforcement: reduced access to trade credit, complications with banking relationships, and the quiet withdrawal of business opportunities that characterise a community built on trust and personal reputation.
Our Dubai team uses this dynamic deliberately. Initial engagement with the debtor is conducted in person, at their offices, by a team member who operates within Dubai's commercial ecosystem. The meeting is respectful, direct, and private. The debtor understands that the conversation represents a professional escalation — not a personal attack — and that further escalation will involve formal legal proceedings that become part of the public record.
In approximately 45% of our Dubai mandates, this initial engagement produces a payment commitment that resolves the claim without court involvement. The percentage is higher than any other jurisdiction we operate in, and it's directly attributable to the reputational dynamics of Dubai's business community.
The $780,000 trading company case
A European industrial chemicals supplier was owed $780,000 by a Dubai-based trading company that distributed their products across the GCC. The trading company had been a reliable partner for four years before payments began slowing, then stopping entirely. The European supplier's regional sales director had maintained a warm relationship with the trading company's owner and was reluctant to escalate — a pattern we see frequently in Dubai, where business relationships often overlap with personal friendships.
Our Dubai team met with the trading company's owner at his offices in Jebel Ali. The conversation, conducted in Arabic, established that the company was solvent but had overextended its credit lines with multiple suppliers simultaneously. Our client was one of seven creditors, and the owner was managing payments based on which creditor was most likely to enforce.
We filed a claim in the Dubai Courts and simultaneously obtained a precautionary attachment order against the trading company's bank accounts at Emirates NBD. The attachment order — granted ex parte within 72 hours of filing — froze sufficient funds to cover the claim. The trading company's owner contacted us within 48 hours of the freeze, and payment of $780,000 was arranged through a structured settlement completed in 35 days.
The European supplier's sales director later acknowledged that the owner's warmth had been genuine throughout — but so had his strategy of paying the most aggressive creditors first.
UAE enforcement instruments
The UAE provides several enforcement tools that international creditors should understand: precautionary attachment of bank accounts and assets (available before judgment in urgent cases), travel bans against individual debtors (available through criminal proceedings for bounced cheques or fraud), and direct enforcement of arbitral awards under the New York Convention and the UAE Arbitration Law (Federal Law No. 6 of 2018).
For creditors whose contracts include bounced cheques — still common in UAE commercial practice despite recent decriminalisation reforms — the cheque itself constitutes prima facie evidence of the debt and provides an expedited enforcement pathway through the execution courts.
If you're owed money by a Dubai-based entity, the debtor's confidence is usually well-funded. The question is whether your claim ranks high enough in their payment hierarchy. Brief our Dubai team to move it to the top.
