Gulf Financial Free Zones Update - 26 May to 13 July 2026

It has been a busy seven weeks since our last note, with all three centres active.

In the DIFC, the Court of Appeal gave three judgments of note: Oqab v Oorhna & Ors [2026] DIFC CA 004 on the scope of the Court's examination power in aid of enforcement, Abramenko & Misevich v Chuprin [2026] DIFC CA 009 on relief from sanctions, and the full-bench decision in Krystal Financial Consultants v Nextgen Robopark [2025] DIFC CA 007 on immediate judgment. At first instance, the cases to read are Justice Michael Black's Digital Economy Court judgment in the Gate Mena / Huobi v Tabarak crypto retrial, Justice Sapna Jhangiani's reinsurance trial in Qatar General Insurance v Emrgent, and two renewed permission-to-appeal refusals by Chief Justice Wayne Martin (in Coinmena v Foloosi and Emirates NBD v Almakhawi).

In the ADGM, the Court of First Instance handed down four reasoned judgments (ADGMCFI 0016–0019), among them two substantial real-property decisions from Justice Paul Heath KC (one on Al Reem, one on Al Maryah), a trust-directions judgment from Justice Sir Andrew Smith and a constructive-dismissal judgment from Justice Sir William Stone SBS KC.

In the QFC, the Appellate Division gave three decisions (duress, cross-border insolvency recognition and employment liquidated damages), Justice James Allsop AC imposed an indemnity-costs sanction for a wrongful criminal complaint in Hashim v Charles Cross, and the Court issued two new Practice Directions on 23 June 2026.

The ADGM Court of Appeal published nothing new, and we found no new DIFC Laws, Regulations, Amendment Laws or Enactment Notices, or new QFC laws, coming into force. The two QICDRC Practice Directions and the recent DIFC consultations are covered at the end.

New judgments: DIFC

Court of Appeal

[2026] DIFC CA 004 - Oqab v (1) Oorhna (2) Oorja (3) Omaran (4) Omika (5) Omnia (link). Court: DIFC Court of Appeal. Date: 3 June 2026. Judgment of the Court of Appeal (H.E. Justice Robert French, H.E. Justice Rene Le Miere and H.E. Justice Thomas Bathurst). Case number: CA 004/2026 (ENF 047/2024). Parties anonymised.

This appeal concerned the scope of the Court's examination power under Part 50 of the RDC, used here in aid of the DIFC Courts' enforcement of a judgment of the Dubai Court of Cassation dated 16 May 2023. The appeal failed because the judge's orders disclosed no error, but the Court of Appeal corrected the judge's reasoning on one point: the examination power is not confined to assets within the DIFC. The Respondent was ordered to pay the Appellant's appeal costs, fixed at AED 373,600, within 28 days. That point will matter to anyone enforcing a foreign or onshore judgment through the DIFC.

[2026] DIFC CA 009 - (1) Roman Abramenko (2) Vadim Misevich v Igor Chuprin (link). Court: DIFC Court of Appeal. Date: 8 June 2026. Judgment of the Court of Appeal (H.E. Deputy Chief Justice Ali Al Madhani, H.E. Justice Robert French and H.E. Justice Rene Le Miere). Case number: CA 009/2026.

An appeal from the Order of H.E. Justice Andrew Moran dated 10 April 2026, which had granted the Defendant relief from sanctions to rely on a witness statement served out of time. The Court dismissed the appeal and ordered the Appellants to pay the Respondent's costs of the appeal, summarily assessed at USD 160,000. The Court's discussion of whether there was a good explanation for the default is the part to read, alongside the first-instance authorities on the same test.

[2025] DIFC CA 007 - Krystal Financial Consultants LLC v Nextgen Robopark Investment LLC (link). Court: DIFC Court of Appeal. Date: issued 16 June 2026, re-issued 24 June 2026. Before H.E. Chief Justice Wayne Martin, H.E. Justice Sir Peter Gross, H.E. Justice Roger Stewart, H.E. Justice Patrick Anthony Keane and H.E. Justice Lim Thiam Suan. Hearing: 20 May 2026. Case number: CA 007/2025.

Krystal appealed the first-instance decision granting Nextgen's application for immediate judgment and dismissing Krystal's claim with costs, permission having been granted below. The appeal was dismissed, and the Appellant was ordered to pay the Respondent's costs of the appeal, fixed at AED 180,701.35, with interest at 9% per annum from the date of judgment if not paid within 21 days. Coming from a five-member bench, the judgment will carry real weight on the immediate-judgment threshold and on how the Court of Appeal treats appeals from summary disposals.

Court of First Instance

CFI 053/2024 - Qatar General Insurance & Reinsurance Company QSPC v Emrgent Risk Solutions Limited (link). Court: DIFC Court of First Instance. Date: 3 June 2026. Judgment of H.E. Justice Sapna Jhangiani. Hearing: 26–29 January 2026.

This was a full trial of a reinsurance dispute. The Court found that the Defendant had breached its obligations under the contract and was liable in damages, ordering payment of QAR 6,089,712.00 in respect of "HOC1" and QAR 146,724.61 in respect of "HOC2" (with further sums continuing to accrue), together with declarations entitling the Claimant to be indemnified for the Defendant's half-share of invoices paid in respect of HOC2 and HOC3, conditional on payment under the underlying Liberty / AON reinsurance. Reasoned reinsurance trial judgments are rare in the DIFC, and this one is worth reading for its treatment of indemnity between co-reinsureds.

DEC 002/2024 -(1) Gate Mena DMCC (formerly Huobi OTC DMCC) (2) Huobi Mena FZE v Tabarak Investment Capital Limited (link). Court: DIFC Digital Economy Court. Date: 17 June 2026. Judgment of H.E. Justice Michael Black. Hearing: 2–6 February 2026.

Justice Black retried a single issue, as the Court of Appeal had ordered on 13 June 2024 (CA-002-2023), after the original TCD trial before Justice Sir Richard Field (now retired) and judgment of 5 October 2022. The Claimants' claim was dismissed, with costs to be dealt with on the papers. The Digital Economy Court has given few judgments so far, so this one will interest anyone advising crypto-exchange and digital-asset counterparties in the DIFC.

CFI 097/2024 - Brand Lounge FZ LLC v Mohamed Hilal Group (link). Court: DIFC Court of First Instance. Date: 16 June 2026. Judgment of H.E. Justice Shamlan Al Sawalehi. Hearing: 5-6 May 2026.

This trial concerned a Branding Services Agreement. The Court awarded the Claimant the value of its unpaid invoices in the sum of AED 913,500, dismissed the claim for additional damages, and dismissed the Defendant's counterclaim in its entirety, with costs to the Claimant on the standard basis (assessed by a separate order the same day). The invoice claim was straightforward; the short passage rejecting the claim for "loss beyond the debt" is the more instructive part.

CFI 118/2025 - Petrichor Energy FZCO v (1) Ultimate Oil & Gas FZCO (2) Alhaji Abdulrahman Musa Bashar (link). Court: DIFC Court of First Instance. Date: 9 June 2026. Order with Reasons of H.E. Justice Rene Le Miere.

The Claimant sought recognition and enforcement of the DIFC Courts' final judgment of the High Court of England and Wales dated 14 February 2025. The Court had dismissed the Defendants' stay application under Article 13(1) of the DIFC Arbitration Law and directed the Claimant's immediate-judgment application to proceed. Justice Le Miere has now given the Defendants permission to appeal on a single ground concerning the proper application of Article 13(1), with the costs of the PTA application reserved to the Court of Appeal. The appeal should tell us how Article 13(1) works where an arbitration stay is sought in answer to a claim to enforce a foreign judgment.

CFI 121/2025 - VTB Bank PJSC v (1) Timur Kuanyshev (2) Evgeny Shlenskikh (3) Shev Energy LLC-FZ (4) Alfiya Kuanysheva (5) Munira Baymenova (link). Court: DIFC Court of First Instance. Date: 11 June 2026. Order with Reasons of H.E. Justice Michael Black.

This costs order follows the Court's earlier committal of the respondents for contempt under Part 52 of the RDC in worldwide freezing order proceedings (the committal order of 15 April 2026 having imposed fines of USD 250,000 on Mr Kuanyshev, USD 150,000 on Mr Shlenskikh, USD 150,000 on Shev Energy and USD 250,000 on Mrs Kuanysheva). The Court awarded VTB its committal application costs of USD 282,020.38 on the indemnity basis against the defendants jointly and severally, adding that it would have assessed the same figure on the standard basis. For asset-recovery practitioners, it is a reminder that contempt in DIFC freezing-order proceedings carries a costs price as well as fines.

CFI 007/2026 - (1) Bimal Gandhi (2) Nishant Kaushik v (1) Muhanad Hisham Mohammed Azzeh (2) PCS Holding Limited (3) I D Centriq Digital Solutions LLC (link). Court: DIFC Court of First Instance. Date: 24 June 2026. Order with Reasons of H.E. Justice Rene Le Miere.

On an application under RDC 4.16, the Court struck out the Claimants' investment claims (misrepresentation and deceit), the Second Claimant's loan claim, and the claims against the Third Defendant, in each case with liberty to apply to amend, and ordered the Claimants to pay the First and Third Defendants' costs of the application, summarily assessed at AED 180,000. Thinly pleaded fraud claims remain exposed under RDC 4.16, though the liberty to amend softened the blow here.

CFI 099/2025 - (1) Pascal Francois Guttiers (2) Deborah Ninette Sheroon Scemama v Mayank Singhvi (link). Court: DIFC Court of First Instance. Date: 19 June 2026. Judgment of H.E. Justice Roger Stewart. Hearing: 17 June 2026.

A Part 8 claim over a property deposit. The Court declared that the Defendant had withdrawn from the transaction, for the purpose of clause 12 of the Agreement of Sale, not later than 7 August 2025, and that the broker was at liberty to release the deposit cheque to the Claimants for encashment and distribution in accordance with clause 12, with costs to be agreed or summarily assessed. The judgment is short and practical on deposit-forfeiture clauses in real-estate sale agreements.

CFI 067/2025 - Coinmena B.S.C (C) v Foloosi Technologies Ltd (link). Court: DIFC Court of First Instance (Court of Appeal permission jurisdiction). Date: 7 July 2026. Order with Reasons of H.E. Chief Justice Wayne Martin.

The Chief Justice refused the Defendant's renewed application for permission to appeal, and a related stay of enforcement, in a payment-gateway debt claim. The order restates the RDC 44.19 "real prospect of success" threshold and rejects strike-out and immediate-judgment attacks premised on alleged pleading deficiencies (a vaguely pleaded oral agreement, an alleged failure to plead loss, and a payee-identity point). The court dismissed both the renewed application and the stay with costs. Anyone pleading an oral agreement or loss in a contract claim, or weighing a renewed permission application, will find it helpful.

CFI 039/2025 – Emirates NBD Bank PJSC v (1) Rashed Almakhawi (2) Abdulaziz Almakhawi (3) Hessa Almakhawi (4) Shamma Almakhawi (link). Court: DIFC Court of First Instance (Court of Appeal permission jurisdiction). Date: 2 July 2026. Order with Reasons of H.E. Chief Justice Wayne Martin.

The Chief Justice dismissed a renewed permission-to-appeal application (and an ancillary application) and ordered the Second Defendant to pay the Claimant's costs of each application by immediate assessment on the standard basis. Read it with Coinmena above for the Chief Justice's approach to renewed applications and what they cost the losing party.

Also handed down (procedural and consequential)

The period also produced a crop of shorter consequential, costs and case-management orders.

New judgments: ADGM

Court of First Instance

[2026] ADGMCFI 0016 - NX (as Trustee of the EYZ Trust) v AA (Beneficiary 1) & Others (PDF). Court: ADGM Court of First Instance (Commercial and Civil Division). Date: 31 May 2026. Judge: Justice Sir Andrew Smith. Case number: ADGMCFI-2026-033. Anonymised; Mr Adam Cloherty KC for the Claimant, Mr Robert Ham KC as amicus curiae.

The trustee of a discretionary family trust applied for directions under the Court's supervisory jurisdiction over trust administration. The Court gave directions confirming that the trustee was validly appointed, that the trust and the 2010 settlement are governed by ADGM law with the ADGM Courts as the forum for administration, that the seat of the settlement is the Abu Dhabi Global Market, that three subsequent deeds were valid in their entirety, and that the trustee had become the absolute beneficial owner of the relevant company shares (held on bare trust by a nominee). The Court drew on the ADGM Application of English Law Regulations 2015, the English Trustee Act 1925 and the Recognition of Trusts Act 1987, and applied Schmidt v Rosewood Trust and Marley v Rawlings. Trustees of family trusts seated in the ADGM now have a clear account of how the Court will approach a request for directions.

[2026] ADGMCFI 0017 - Al Khaleej Investment P.S.C v Ocean Pearl Real Estate Comp LLC (PDF). Court: ADGM Court of First Instance (Real Property Division). Date: 5 June 2026. Judge: Justice Paul Heath KC. Case number: ADGMCFI-2025-143. Hearing: 10 February 2026.

A purchaser's claim for specific performance of a 24 December 2024 sale-and-purchase agreement for land on Al Reem Island (purchase price AED 105 million; an AED 21 million security cheque paid on execution), arising out of the transition of title from the Abu Dhabi Real Property Register to the ADGM Register. The Court held the agreement to be binding and enforceable, granted specific performance, dismissed the counterclaim, and awarded the Claimant its costs on the standard basis. Justice Heath deals with the interaction of lex fori (ADGM law governing remedies and procedure) and lex situs (governing rights in the land), the discretionary nature of equitable remedies, and frustration and estoppel by convention, engaging Cabinet Resolution No. 41 of 2023 and the ADGM Real Property Regulations 2015 and 2024. Anyone with an Al Reem land sale caught in the move from the Abu Dhabi register to the ADGM register should read it.

[2026] ADGMCFI 0018 - A32 v B32; A35 v B35 (PDF). Court: ADGM Court of First Instance (Commercial and Civil Division). Date: 9 June 2026. Judge: Justice Paul Heath KC. Case numbers: ADGMCFI-2025-373 and ADGMCFI-2026-114 (joint judgment). Anonymised. Hearing: 10 April 2026.

An application to set aside an arbitral award seated in onshore Abu Dhabi, and a cross-application to enforce it by specific performance, concerning an option agreement over a unit on Al Maryah Island. The Court dismissed the set-aside application – holding that it could not exercise the section 58 set-aside jurisdiction of the ADGM Arbitration Regulations 2015 over an onshore-seated award (the application also being time-barred and brought under the wrong procedural law) – and granted the enforcement application, ordering transfer of the title deed with the ADGM Registration Authority, with a costs order nisi in A32's favour. Along the way, the judgment deals with the limits of ADGM's opt-in jurisdiction (Abu Dhabi Law No. 4 of 2013), the arbitrability of ADGM real-property disputes (applying FamilyMart v Ting Chuan and Privinvest), and the use of the enforcement jurisdiction to give effect to an award by specific performance. The Court distinguished A6 v B6 [2023] ADGMCFI 0005. The decision matters to real-property arbitrations whether seated in the ADGM or onshore in Abu Dhabi.

[2026] ADGMCFI 0019 - Malvern Tarirai Takawira v Plus Capital Limited (PDF). Court: ADGM Court of First Instance (Employment). Date: 23 June 2026. Judge: Justice Sir William Stone SBS KC. Case number: ADGMCFI-2025-413. Hearing: 11 June 2026.

The Claimant resigned after his employer voluntarily gave up its FSRA Financial Services Permission, and then sued for constructive dismissal and related breaches of the ADGM Employment Regulations. The claim (five heads totalling approximately AED 1.97 million) was dismissed: the Court found no repudiatory breach and no constructive dismissal at common law or under section 57 of the Employment Regulations, holding that the loss of the Compliance Officer / MLRO role was a redundancy consequent on corporate reorganisation rather than conduct aimed at the employee. The Claimant was ordered to pay the Defendant's costs on the standard basis. Applying Western Excavating (ECC) Ltd v Sharp, the judgment maps ADGM's statutory "termination for cause" under section 57 onto common-law constructive dismissal and confirms that regulatory-licence-driven redundancy is not, without more, a repudiatory breach.

New judgments: QFC / QICDRC

Appellate Division

[2026] QIC (A) 10 - Kashif Kamal Raja v Patron Network LLC (PDF). Court: QFC Civil and Commercial Court, Appellate Division. Date: 4 June 2026. Before Lord Thomas of Cwmgiedd (President), Justice Ali Malek KC and Justice Helen Mountfield KC. Case number: CTFIC0029/2025 (on appeal from [2025] QIC (F) 41).

The Court granted permission to appeal and allowed the appeal. The Court set aside the order below (which had stayed the claim to enforce a settlement agreement) and remitted the claim to the First Instance Circuit, finding a triable case that consent to the settlement had been vitiated by duress under Article 36 of the QFC Contract Regulations 2005. The Respondent was ordered to pay the Appellant's costs of the appeal. The Appellate Division's treatment of duress, and of when a claim to enforce a compromise should be stayed, is worth reading.

[2026] QIC (A) 11 - RE RTI Limited (In Liquidation) (PDF). Court: QFC Civil and Commercial Court, Appellate Division. Date: 9 June 2026. Before Lord Thomas of Cwmgiedd (President), Justice Sir William Blair and Justice Dr Hassan Al-Sayyed. Case number: CTFIC0015/2026 (on appeal from [2026] QIC (F) 15).

Al Plus Holdings LLC sought permission to appeal against a cross-border insolvency recognition order (under Article 163 of the QFC Insolvency Regulations 2005) recognising the Jersey liquidation of RTI Limited. Permission was refused and the application declared totally without merit: the applicant had no standing to challenge a recognition-only order, any substantive dispute being a matter for a future Article 168 application. In short, a party unhappy with a recognition order should wait for any substantive application rather than attack recognition itself.

[2026] QIC (A) 12 – Cheikh Tidiane Niang v Clement Sports QFC LLC (PDF). Court: QFC Civil and Commercial Court, Appellate Division. Date: 14 June 2026. Before Lord Thomas of Cwmgiedd (President), Justice Dr Muna Al-Marzouqi and Justice Dr Talal Al-Emadi. Case number: CTFIC0053/2025 (on appeal from [2026] QIC (F) 11).

An employee sought permission to appeal an order requiring him to pay QAR 9,500 in liquidated damages under his employment contract. Permission was refused on all grounds, the Court holding that the First Instance Circuit had correctly applied Article 107 of the QFC Employment Regulations 2005 (following Zishan Anwar v Devisers Advisory Services [2025] QIC (A) 9). Employers can take some comfort that liquidated-damages clauses in QFC employment contracts will be enforced.

First Instance Circuit

[2026] QIC (F) 38 - Ahmed Saleh & Ahmed Sabra & Dino Palazzi v Nexus Financial Services WLL (PDF). Court: QFC Civil and Commercial Court. Date: 28 June 2026. Judge: Justice Sir William Blair. Case numbers: CTFIC0056/2025, CTFIC0059/2025 and CTFIC0060/2025 (consolidated).

The Defendant's "reverse" summary judgment application to dismiss the claims as time-barred and unmeritorious was dismissed, with costs reserved to trial. The Court held that QFC law on the postponement of limitation for deliberate concealment (argued by analogy to section 32(1) of the English Limitation Act 1980, against Article 108 of the QFC Contract Regulations) is "in active development" and unsuitable for summary determination. The limitation and concealment point therefore remains open for trial.

[2026] QIC (F) 32 - Ahmed Mahmoud Hashim v Charles Cross - London LLC (PDF). Court: QFC Civil and Commercial Court. Date: 14 June 2026. Judge: Justice James Allsop AC. Case number: CTFIC0062/2025.

An employment claim for unpaid salary and benefits, with a counterclaim. The Court ordered the Defendant to pay the Claimant QAR 597,496.20, with interest, and dismissed the counterclaim with costs. The Court also ordered the Defendant to pay, on an indemnity basis, the Claimant's costs relating to the wrongful filing of a criminal complaint against him. Employers tempted to answer a salary claim with a criminal complaint should weigh the risk of costs.

[2026] QIC (F) 40 - Tamam Capital for Commercial Mediation LLC v Growth Investment Holding LLC & Hamad Mubarak Al Hajri (PDF). Court: QFC Civil and Commercial Court. Date: 29 June 2026. Judge: Justice Fritz Brand. Case number: CTFIC0037/2026.

The reasons for a 25 June 2026 order on the Defendants' urgent application for interim relief restraining the Claimant's director from social-media publications about the litigation. The Claimant's without-prejudice undertaking (not to publish documents confidential under Practice Direction No. 1 of 2023, nor to assert that the Court had made any final determination of liability) was made an order, without any finding on the merits. It is one of a series of injunction and asset-preservation orders in this dispute, which earlier required preservation of value equivalent to QAR 30 million.

[2026] QIC (F) 41 - J v K (PDF). Court: QFC Civil and Commercial Court. Date: 1 July 2026. Before Justice Fritz Brand, Justice Helen Mountfield KC and Justice James Allsop AC. Case number: CTFIC0064/2025. Anonymised.

The Court refused an application to relist a trial fixed for 19–20 August 2026. The Court reiterated its practice of fixing hearing dates based on judges' availability rather than the parties', given that it is not a standing court of full-time judges, and declined to allow the trial to slip into 2027 to the Claimant's prejudice. Parties should expect little weight to be given to counsel and witness availability when QFC trial dates are fixed.

[2026] QIC (F) 19 - RE Practice Direction No. 1 of 2024 (Litigation Restraint Orders), In the Matters of Amberberg Limited and Rudolfs Veiss (PDF). Court: QFC Civil and Commercial Court. Date: 31 May 2026. Judge: Justice Fritz Brand. Case number: CTFIC0035/2026.

A Litigation Restraint Order originally made on 5 June 2024, and due to expire on 5 June 2026, was renewed for a further two years under paragraph 4 of Practice Direction No. 1 of 2024, continuing the restraint on the respondents from filing fresh claims or applications without permission.

[2026] QIC (C) 6 - Ibrahim Al-Nasr & Ali Al-Maadeed v Nexus Financial Services WLL (PDF). Court: QFC Civil and Commercial Court (costs). Date: 25 June 2026. Registrar: Mr Umar Azmeh. Case number: CTFIC0032/2024.

A detailed costs assessment following trials and an appeal in which the Claimants were unsuccessful. The Defendant's total reasonable costs were assessed at QAR 907,450, apportioned between the Claimants and including QAR 283,115 of allowable appellate costs, applying Article 34 of the Court's Rules and Procedures. It also shows how an indemnity-basis order affects proportionality on a QFC assessment.

Regulations, Rulebooks and Practice Directions

QFC / QICDRC - two new Practice Directions, 23 June 2026. The QFC Civil and Commercial Court issued Practice Direction No. 2 of 2026 (Default Judgment) and Practice Direction No. 3 of 2026 (Litigants-in-Person – Hourly Rates), both dated 23 June 2026 and signed by Lord Thomas of Cwmgiedd as President (PD No. 3 co-signed by Sir William Blair as Chairman of the QFC Regulatory Tribunal). PD No. 2 of 2026 (PDF) requires a claimant seeking default judgment under Article 22 to file a witness statement addressing service within 28 days of the failure to file a defence. PD No. 3 of 2026 (PDF) sets the litigant-in-person hourly rate for costs orders at QAR 200 per hour, subject to Registrar discretion.

DIFC - open and recent consultations. The DFSA / DIFC ran two consultations during the period. The DIFC Data Protection Regulations consultation (proposed amendments to embed safety in AI-native personal-data processing and to clarify certification obligations and the role of the Autonomous Systems Officer) is open for comment until 18 July 2026. The DIFC Arbitration Law consultation (enhanced tribunal powers, summary determination, security for costs, emergency-arbitrator enforcement and a new mediation framework) closed for comment on 10 July 2026. The earlier Prescribed Company Regulations consultation closed on 2 June 2026. No new DIFC Laws, Regulations, Amendment Laws or Enactment Notices were confirmed as coming into force in the period. (The Regulatory Law Amendment Law, DIFC Law No. 2 of 2025, in force since 30 October 2025, has yet to appear in the publicly indexed Amendment Laws.)

ADGM - no new instrument in force in the period. No new ADGM FSRA or Registration Authority instrument was identified as coming into force between 26 May and 13 July 2026. The FSRA's finalised enhancements to its anti-money laundering framework (21 May 2026, implementing Consultation Paper No. 1 of 2026) and the Registration Authority's commercial-legislation refresh (1 May 2026) were covered in earlier updates.

QICDRC and DIFC Practice Directions; otherwise, nothing new. Aside from the two new QICDRC Practice Directions above, no further new DIFC or QICDRC Practice Directions, Practical Guidance Notes or Registrar's Directions were issued in the period. The most recent DIFC Practice Direction remains PD 1/2025 (Access to Justice in Employment Disputes, 9 October 2025).