The ADGM Court of First Instance, which had not handed down a substantive judgment since 22 April 2026, has just handed down two, both by Justice William Stone SBS KC, in the same week: Ali Othman A Alrakban v Webridge Properties LLC [2026] ADGMCFI 0014 (the first ADGM application of the Off-Plan Development Regulations 2024, awarding damages in lieu of rescission for misrepresentation by a property developer, and Sulaiman Ali Adnan Zahir Mohammed Amin v Edwin Holdings Ltd & Anor [2026] ADGMCFI 0015, a repudiation claim raising the enforceability of a daily-penalty clause and the limits of personal liability against a director).

The QFC Civil and Commercial Court has published Red Dot Films v Hoot Media LLC [2026] QIC (F) 16, a short Brand J debt-recovery judgment involving a non-QFC counterparty and the article 9.1.1.3 jurisdictional gateway.

In the DIFC, the Court of First Instance has handed down Stephan Karl Morgenstern v Saif Sultan Al Mehrzi Lawyer & Legal Consultants [2025] DIFC CFI 036 (H.E. Justice Roger Stewart) for AED 1.5m against a firm of lawyers, and an Amended Order with Reasons (H.E. Justice Thomas Bathurst) in Sanja Boskovic v Mirabaud (Middle East) Ltd CFI 064/2025.

On the regulatory side, the FSRA finalised its enhancements to the ADGM anti-money laundering framework on 21 May 2026, implementing the proposals in Consultation Paper No. 1 of 2026 by revising the Financial Services and Markets Regulations 2015 and the Anti-Money Laundering and Sanctions Rulebook.

New judgments

ADGM

[2026] ADGMCFI 0014 — Ali Othman A Alrakban v Webridge Properties LLC Court: ADGM Court of First Instance. Date: 19 May 2026 Judge: Justice William Stone SBS KC Case number: ADGMCFI-2025-367 Provisions: Abu Dhabi Law No. 3 of 2015; Application of English Law Regulations 2015; Off-Plan Development Regulations 2024; Federal Decree-Law No. 8 of 2017 and its Executive Regulations (VAT); Federal Law No. 5 of 1984 (Civil Transactions).

Stone J's substantive trial judgment is, on its face, the more significant of the two new ADGM First Instance items this week and the first ADGM application of the Off-Plan Development Regulations 2024. This was a misrepresentation claim by an off-plan purchaser against the developer, the principal issues being whether value-added tax was included in the agreed purchase price and the condition of the property on handover. After hearings on 23 April and 4 May 2026 the Court ordered the Defendant to pay the Claimant damages in lieu of rescission of AED 2,976,455 together with interest at 5% per annum from the date of judgment until payment, and dismissed the Defendant's counterclaim. A costs order was made requiring the Defendant to pay 70% of the Claimant's costs of the Claim and Counterclaim, with assessment on the papers on the standard basis if not agreed, the order to become absolute absent any application to vary within 14 days. The judgment will be a useful for advisers on off-plan transactions in the ADGM where the structure of the VAT proviions and the warranties as to condition on handover may, in combination, support damages in lieu of rescission rather than outright termination, and a first reference point on how the 2024 Regulations will be read in practice.

[2026] ADGMCFI 0015 — Sulaiman Ali Adnan Zahir Mohammed Amin v Edwin Holdings Ltd & Anor Court: ADGM Court of First Instance. Date: 22 May 2026 Judge: Justice William Stone SBS KC Case number: ADGMCFI-2025-462 Issues: admitted breach of settlement agreement; enforceability of daily-penalty clause; personal guarantees; negligent misstatement; separate legal personality of company.

Stone J's second judgment of the week, following a hearing on 17 April 2026. The First Defendant company admitted a breach of a settlement agreement. The issues were (i) the enforceability of a clause within the settlement agreement providing for a daily penalty upon breach, and (ii) whether the company's payment obligations were also personally undertaken by its director (the Second Defendant) on the basis of a personal guarantee or by way of a negligent misstatement assuming personal responsibility for the company's obligations. The Court declared the daily penalty clause unenforceable, entered judgment for the Claimant against the First Defendant in the sum of AED 918,000 with interest at 5% per annum from 5 November 2025 until payment, and dismissed the claim against the director, preserving the comapny's separate legal personality. Costs are to be determined on the papers. A restatement of the orthodox position on penalties, the personal-versus-corporate liability under a settlement, and the limits of negligent misstatement as a route round Salomon.

QFCDRC

[2026] QIC (F) 16 — Red Dot Films v Hoot Media LLC Court: Qatar Financial Centre. Date: 19 May 2026 Judge: Justice Fritz Brand Case number: CTFIC0001/2026 Provisions: QFC Court's Rules and Procedures, article 9.1.1.3.

A short Brand J debt-recovery judgment. The Claimant (a Qatar-incorporated company (not QFC-registered) specialising in cinematography and the rental of filming equipment) submitted a written quotation on 12 February 2025 for the five-day rental of professional filming equipment to the Defendant (a QFC-licensed company) for a film shoot in the State of Qatar, accepted by the Defendant's authorised signatory on the same day. The agreed equipment list included a remote controlled drone. The Court ordered the Defendant to pay the Claimant QAR 106,000, together with interest at the rate of 5% per annum from 3 March 2025 until the date of actual payment, plus the Claimant's reasonable costs to be assessed by the Registrar if not agreed. Two points of interest. First, this is an illustration of the article 9.1.1.3 jurisdictional gateway (a commercial dispute arising from a contract between a QFC-established entity and an entity established in the wider State of Qatar) and is a useful case for cross-border QFC contract claims with non-QFC counterparties. Second, Brand J's willingness to award interest from the date of breach (here, 3 March 2025) rather than from the date of the claim form, a point of difference from some other courts in the region.

DIFC Court of First Instance

Stephan Karl Morgenstern v Saif Sultan Al Mehrzi Lawyer & Legal Consultants [2025] DIFC CFI 036 (Claim No. CFI 036/2025). Judgment of H.E. Justice Roger Stewart.

The Claimant brought a Part 7 claim against a firm of lawyers to recover AED 1,412,950 plus interest pursuant to the express terms of a contract. The trial was held remotely on 11 May 2026. Stewart J held there was no defence to the claim and entered judgment for AED 1,412,950 together with interest to the date of judgment of AED 92,292.69. Post-judgment interest runs at 9% per annum (AED 348.40 per day). A neat illustration of contractual recovery against a professional-services counterparty under an express contractual term.

Sanja Boskovic v Mirabaud (Middle East) Ltd CFI 064/2025. Amended Order with Reasons of H.E. Justice Thomas Bathurst (originally issued 13 May 2026; re-issued in amended form on 20 May 2026).

The amended order disposes of the Claimant's Application No. CFI-064-2025/2 dated 13 February 2026 seeking document production, and the Claimant's Application No. CFI-064-2025/3 dated 27 February 2026 seeking permission to adduce expert evidence, following the Progress Monitoring Date listed before Bathurst J on 14 May 2026. An interlocutory case-management ruling rather than a substantive disposal, but worth reading for the framework Bathurst J adopts on document production and expert-evidence permissions at the case-management stage in CFI proceedings.

Regulations, Rulebooks and Practice Directions

ADGM — FSRA finalises enhancements to its AML framework, 21 May 2026.

The Financial Services Regulatory Authority of the ADGM has finalised the proposals set out in Consultation Paper No. 1 of 2026 (Proposed Enhancements to the Anti-Money Laundering Framework of the FSRA), the consultation having closed on 14 May 2026. Appropriate revisions have been made to the Financial Services and Markets Regulations 2015 (FSMR) and the Anti-Money Laundering and Sanctions Rulebook (the AML Rulebook), said by the FSRA to reflect developments in federal laws and to align with evolving international best practice on anti-money laundering, counter-terrorist financing, counter-proliferation financing and sanctions. The amendments apply across the regulated sector, financial services firms, virtual asset service providers, DNFBPs and any other Authorised Person or Recognised Body subject to the AML Rulebook, and follow industry engagement and feedback from the consultation.