Dubai Confirms the Allocation of Jurisdiction Over the Recognition and Enforcement of Foreign Arbitral Awards

Short summary

Dubai's Conflicts of Jurisdiction Tribunal clarified that foreign arbitral award recognition falls to DIFC Courts regardless of arbitration seat, while enforcement outside DIFC jurisdiction goes to onshore Dubai Courts under the New York Convention. Award creditors may find direct application to onshore courts more cost-effective. This resolves jurisdictional conflicts between DIFC and onshore judicial authorities.

• •DIFC Courts have jurisdiction to recognize foreign arbitral awards regardless of seat
• •Enforcement outside DIFC falls to onshore Dubai Courts
• •Clarifies division under New York Convention and UAE Federal Law No. 42 of 2022

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