Moscow Arbitrazh Court judgment enforced in the UAE

The task

The client was a manufacturer from St Petersburg; the debtor, a company registered in the UAE. The client already held a final judgment of the Moscow Arbitrazh Court, but there was nothing to enforce against in Russia: the debtor's assets were in the Emirates. The task was to enforce the judgment in the UAE.

How a Russian judgment is usually enforced in the UAE

We do not disclose the internal details of client matters, but this is the typical sequence in such cases:

1. Assess the judgment. Is it final? Was the debtor properly notified of the proceedings? Does it conflict with UAE public order, or with a UAE judgment on the same dispute?
2. Documents. A certified copy of the judgment, confirmation that it is final, and proof of service on the debtor. The documents are legalised for the UAE through the consular chain and translated into Arabic.
3. Application to the execution judge. Under the UAE Civil Procedure Code (Federal Decree-Law No. 42 of 2022), a foreign judgment is enforced on application to the execution judge. Russia and the UAE have no bilateral treaty on the mutual recognition of civil judgments, so reciprocity is the central issue and has to be demonstrated.
4. Enforcement. Once the enforcement order is granted, an execution file is opened: the debtor's accounts and assets are traced and attached.

See Enforcing Russian and CIS judgments in the UAE and our article Enforcing a Russian court judgment in the UAE, step by step.

The result

The Moscow Arbitrazh Court judgment was recognised in the UAE and the debtor's accounts were frozen, within 9 months. The client never travelled to the Emirates: the matter ran on a power of attorney, with weekly reports.

Recognition of a foreign judgment in the UAE is not a formality: the court checks the conditions and the debtor may object. If you hold a Russian or Kazakh judgment against a UAE company, start with a review of the documents.