When you need a foreign judgment enforced in the UAE
A Russian or Kazakh judgment has no direct effect in the Emirates: a Dubai bank will not debit a debtor's account on the strength of a Moscow writ. To make the judgment work, it must be recognised and declared enforceable by a UAE court. Only then does the creditor gain access to the local enforcement machinery.
Typical situations we see:
- a Russian or CIS company has won a dispute against a UAE counterparty that still refuses to pay;
- the debtor is an individual who has moved to the UAE and holds accounts or property here;
- there is an arbitral award (for example from the ICAC in Moscow) to be enforced against a Dubai company.
If you do not have a judgment yet, first consider where it makes more sense to sue — see debt recovery in the UAE.
The legal basis: court judgments and arbitral awards
Court judgments. Recognition of foreign judgments by the onshore UAE courts is governed by the Civil Procedure Law, Federal Decree-Law No. 42 of 2022. Where a treaty is in force between the UAE and the country of origin, its rules take precedence. Without a treaty, the key test is reciprocity: the court looks at whether UAE judgments are enforced in the country where the judgment was given.
The court will usually also check that:
- the judgment is final and binding;
- the foreign court had jurisdiction and the UAE courts did not have exclusive jurisdiction;
- the defendant was properly served and had a fair opportunity to defend;
- the judgment does not conflict with an earlier UAE judgment or with UAE public order.
Arbitral awards. The UAE has been party to the 1958 New York Convention on foreign arbitral awards since 2006, and Russia is a party too. Awards made in Russia and most CIS states are therefore enforced under more predictable rules than state court judgments. More on this on our DIAC arbitration page.
How the process works
- Review of the judgment and assets. We confirm the judgment is final, check how the defendant was served and locate the debtor's accounts, shares and property. This decides which emirate and which court to apply to.
- Documents. A certified copy of the judgment, proof of finality and service, and a power of attorney. Documents are authenticated to UAE requirements and translated into Arabic.
- Application to the execution judge. The application for recognition and enforcement is filed with the competent UAE court. Together with a UAE-licensed advocate with rights of audience, we prepare the evidence of reciprocity and the answer to the debtor's objections.
- Interim measures. Where assets may be moved, we seek attachment of accounts and property as early as possible.
- Enforcement. Once recognised, the judgment is enforced like a local one: freezing and debiting bank accounts, attaching real estate and shares, and other measures available under the law.
The DIFC and ADGM Courts apply their own rules on recognising foreign judgments. The right route depends on where the debtor's assets are.
Our track record: a Moscow Arbitrazh Court judgment enforced in the UAE
A St Petersburg manufacturer won a dispute against a UAE company in the Moscow Arbitrazh Court. We obtained recognition of the judgment in the UAE, after which the debtor's accounts were frozen. It took 9 months. Read the full case, or our step-by-step article on enforcing a Russian court judgment in the UAE.
Every matter is different: the outcome depends on the judgment itself, the evidence of reciprocity, the debtor's defence and whether the debtor has assets. No one can honestly guarantee the result.
Timing, risks and fees
Timing depends on the emirate, the court's workload, whether reciprocity must be proven and whether the debtor appeals recognition. The main risks are assets being moved before they are frozen, procedural flaws in the foreign proceedings (such as defective service) and a debtor with no assets in the UAE. That is why we start with a 1–2 day diagnosis and give you a candid view of your prospects.
Fee models: a fixed project fee from AED 5,000, or a success fee of 10–25% of the amount recovered plus a fixed element. Court fees and translations are charged separately and listed in the estimate. The matter can run entirely remotely under a power of attorney, with a weekly progress report.
FAQ
Yes, it is possible: UAE courts recognise foreign judgments when the statutory conditions are met, above all reciprocity and proper service on the defendant. We assess your prospects once we have reviewed the judgment.
Arbitral awards are enforced under the New York Convention, to which both the UAE and Russia are parties. Court judgments are recognised under the UAE Civil Procedure Law and any applicable treaty, where reciprocity is the central question.
No. We act under a power of attorney that you can sign in your own country, and meetings take place by video.
Where there is a risk of assets being moved, we can apply for interim measures. Whether and when an attachment is granted depends on the stage of the case and the court.