Author: afridi-angell

Responsibilities and Code of Ethics for Real Estate Brokers in Dubai

Dubai’s property market continues to grow at record pace, attracting buyers from around the world. With this growth comes closer scrutiny of real estate brokers, who play a key role in keeping the market transparent, trustworthy, and compliant with regulations.

 

Why Broker Regulations Matter

Dubai strictly regulates real estate brokerage to protect investors and ensure fair dealings. Only trained, licensed, and registered brokers can broker real estate transactions. Regulatory bodies the Dubai Land Department (DLD) and the Real Estate Regulatory Agency (RERA) enforce clear rules, monitor behaviour, and penalise violations such as misleading ads or unlicensed activity.

 

What Brokers Must Do

Brokers in Dubai have legal duties that go far beyond connecting buyers and sellers. These include:

 

Holding proper licences and registrations: brokers must complete RERA training, pass exams, and carry valid broker IDs.

 

Keeping clear records: all transaction documents must be properly maintained and shared with clients when requested.

 

Being transparent: brokers must clearly disclose all relevant information, negotiation terms, and conditions.

 

Acting lawfully and in good faith: facilitation of any unlawful deal, or acts of fraud or deception, can lead to loss of commission and legal penalties.

 

Safeguarding client money: any funds or cheques entrusted to a broker must be protected and used only as agreed.

 

Earning commission properly: fees are due only when the broker successfully concludes the deal and fulfils agreed conditions.

 

Sharing liability when multiple brokers are involved: unless agreed otherwise, responsibility is joint.

 

Ethical Standards Brokers Must Follow

RERA’s Code of Ethics requires brokers to uphold professionalism at all times. Core expectations include:

 

Honesty, integrity, and respect: privacy, dignity, and transparency must guide all interactions.

 

Following all laws and regulations: no misleading advertising, false claims, or unauthorised activities.

 

Protecting documents: brokers must preserve all records linked to transactions.

 

Respecting DLD procedures: professional conduct is mandatory; personal connections may not be used to influence processes.

 

Practical Obligations in the Transaction Process

To safeguard buyers and sellers, brokers must comply with several operational rules:

 

Use RERA-standard forms: Form A (Seller), Form B (Buyer), and Form F/C (Sale).

 

Disclose commissions upfront: usually 1–5%, and always written in the contract.

 

Verify property ownership and documents: due diligence is mandatory.

 

Follow escrow (trust) account rules for off-plan projects: all payments must go into RERA-approved escrow accounts, not to brokers or to developers.

 

Advertise responsibly: Ads require RERA approval and must be accurate and non-misleading.

 

Meet AML/KYC requirements: brokers must verify client identity and report suspicious activity.

 

How Compliance Is Enforced

DLD and RERA actively monitor brokers through inspections, licence renewals, and mandatory training. Penalties for breaches are significant — including fines, warnings, and suspension of agents. Complaints from consumers can be filed directly with DLD, and unresolved matters can proceed to Dubai Courts.

 

Why This Matters to Consumers and Brokers

Dubai’s real estate success depends on transparency and trust. Licensed, ethical brokers have assisted to strengthen the market over decades; unprofessional practices damage the market overnight.

 

For brokers, professionalism is not optional. It is the foundation of credibility in a tightly regulated market. ■

Amendments to the UAE Federal Companies Law – Key Changes

The UAE recently introduced Federal Decree-Law 20 of 2025 (the CCL Amendment) amending several provisions of Federal Decree-Law 32 of 2021 regarding commercial companies (the Companies Law). Certain key provisions of the Companies Law have been amended in order to: give clarity on its scope; introduce common law principles and rules surrounding non-profit companies, as well as flexibility in structuring shareholding arrangements. These amendments came into effect on 15 October 2025.

 

Applicable to free zones

The CCL Amendment provides that the provisions of the Companies Law apply to branches or representative offices of free zone companies established on mainland UAE (i.e. outside of the free zone areas). The Companies Law does not apply to companies incorporated in UAE free zones where the relevant free zone’s laws and regulations contain specific provisions disapplying the provisions of the Companies Law.

 

Most free zones of the UAE have their own laws and regulations. However, if a free zone’s laws and regulations do not contain specific provisions excluding the provisions of the Companies Law, the provisions of the Companies Law may apply in addition to its own laws and regulations. Furthermore, there are certain free zones in the UAE that do not have their own laws and regulations and, in those cases, the provisions of the Companies Law may apply. When addressing any corporate law issues, it is crucial for a free zone company to consider if the Companies Law will apply to that free zone company and the impact of those provisions on its company.

 

The CCL Amendment re-affirms that free zone companies are considered to hold the nationality of the UAE. This aspect is important from the perspective of UAE corporate tax and double taxation treaties which may be entered into between the UAE and other countries.

 

Flexibility in shareholding and share transfers

 

One of the most notable changes is the introduction of shareholder-rights mechanisms. Limited liability companies (LLCs) and private joint stock companies may now include drag-along and tag-along rights in their Memoranda of Association and by-laws. Further, the CCL Amendment provides for a structured succession approach where, in the event of a shareholder’s death, remaining shareholders have a right of first refusal over the shares of the deceased shareholder, with valuation determined, by agreement, with the legal heirs or by the competent court (in the case of non-agreement). The Memoranda of Association and by-laws must include provisions regarding the right of first refusal.

 

Classes of shares

 

The CCL Amendment now permits the issuance of different classes of shares. These shares may, for example, have different rights and restrictions in terms of value, voting rights, redemption rights, priority in the distribution of profits or liquidation, etc. Memoranda of Association and by-laws of LLCs will be required to have specific provisions regarding the issuance of different classes of shares. The Cabinet will determine the categories of different classes of shares and set out the respective conditions of each category of those shares.

 

Companies looking at restructuring their shareholding and issuance of different classes of shares would be advised to wait for the issuance of further guidance by the Cabinet. It is worth noting that there are free zones in the UAE where the issuance of different classes of shares is currently permitted.

 

Re-domiciliation and cross-jurisdiction mobility

 

The CCL Amendment introduces the concept of re-domiciliation of companies. This new option permits a company to move its corporate registration from one jurisdiction to another without dissolving the company or creating a new legal entity. Subject to the satisfaction of certain criteria, a company may transfer its jurisdiction of incorporation from one Emirate to another or from a free zone to mainland or vice-versa.

 

The provisions are silent on foreign companies transferring their jurisdiction of incorporation to mainland UAE. However, there are certain free zones in the UAE where a foreign company can transfer its domicile.

 

Non-profit companies

 

The CCL Amendment specifically provides for the incorporation of non-profit companies. The net profits of a non-profit company are required to be reinvested in the company in order to achieve the company’s objectives. The profits cannot be distributed to its partners or shareholders. The Cabinet is expected to issue further clarification regarding the prescribed purposes of such non-profit companies as well as regulations governing such non-profit entities.

 

Improved governance mechanism

 

The CCL Amendment introduces a more expedient approach for resignation, removal, and continuity rules for mainland LLCs’ managers. A decision on a manager’s resignation must be taken by the shareholder(s) within 30 days of the submission of such resignation otherwise the manager’s resignation will be considered automatically effective. This period has been reduced from the initial 40 days to 30 days.

 

It remains to be seen if the local licensing authorities will record a resignation by a manager and remove a manager’s name from an LLC’s license in the absence of an appointment of a replacement by the shareholders.

 

Conclusion

 

The CCL Amendment is important in that it expands the scope of mainland LLCs and offers greater flexibility.

 

Previously, when structuring a joint venture entity with complex shareholding arrangements, shareholders tended to opt for an offshore jurisdiction or free zone for ease of doing business and flexibility. Now however, the CCL Amendment provides the option to structure these same arrangements locally without the need for a holding company structure. It will be interesting to observe how these provisions are practically implemented by local authorities. ■

Mergers & Acquisitions (UAE chapter), Lexology In-Depth

This multi-jurisdictional reference guide features a UAE chapter, authored by Danielle Lobo (partner), Abdus Samad (partner) and Alexander Grant (associate), and provides a practical overview of global M&A activity and the legal and regulatory frameworks governing M&A transactions in major jurisdictions worldwide. With a focus on recent developments and trends, it examines key issues, including the relevant competition, tax, and employment law considerations; financing; due diligence; and much more.

New Anti-Money Laundering Law – Federal Decree-Law 10 of 2025

Introduction

 

The United Arab Emirates (UAE) has enacted Federal Decree-Law 10 of 2025 Regarding Combating Money Laundering Crimes, Combating the Financing of Terrorism and the Financing of Arms Proliferation (the New AML Law), replacing the 2018 legislation and further strengthening the UAE’s alignment with international financial crime standards. The framework introduces expanded definitions, new and updated offences, enhanced preventive obligations and broader supervisory and investigative powers. It also anticipates the risks associated with digital system misuse, virtual asset channels and the UAE’s developing tax landscape, ensuring that the regulatory regime can respond effectively to emerging financial crime threats.

 

Expanded predicate crimes and updated core definitions

 

The reform begins with significantly broader and more precise definitions. The term “Predicate Crime” now expressly includes terrorist financing, proliferation financing, and both direct and indirect tax evasion, along with any felony or misdemeanour under UAE law, whether committed within or outside the UAE. This refinement ensures that a wider range of conduct, including tax-related offences, can give rise to “criminal property” and therefore fall within the anti-money laundering regime, an important development in the context of the UAE’s corporate tax framework.

 

Core definitions have also been modernised. “Funds” now encompass digital and encrypted assets, and “Criminal Property” extends to instruments and assets used or intended to be used in terrorism or proliferation-related activity. The definition of “Money Laundering” explicitly captures conduct executed through digital systems, encrypted platforms and virtual asset channels, ensuring that the regime keeps pace with technological developments and the shifting methods by which illicit value is moved.

 

These refinements broaden the legal foundation of the framework and enhance regulators’ ability to address a more diverse and technologically complex risk environment.

 

Express inclusion of proliferation financing

 

A significant expansion included proliferation financing, which is now treated as a distinct and fully articulated offence. The New AML Law defines “proliferation of arms” to include activities relating to the manufacture, acquisition, transfer or stockpiling of weapons of mass destruction and their delivery systems, and criminalises the provision or collection of funds in support of such activities. Importantly, knowledge may be inferred from factual and objective circumstances, enabling authorities to take action even where direct evidence of intent is limited, but surrounding indicators strongly suggest an illicit purpose.

 

By expressly incorporating proliferation financing and lowering the evidentiary threshold, the framework aligns more closely with global non-proliferation standards and strengthens the legal basis for enforcing targeted financial sanctions measures, thereby ensuring that businesses operating in the UAE maintain robust controls and remain vigilant to potential exposure to proliferation-related risks.

 

Digital systems and virtual asset coverage

Another area of significant development is the treatment of digital systems and virtual asset activity, reflecting the growing relevance of technology-driven financial channels. “Virtual Assets” and “Virtual Asset Service Providers” (VASPs) are now expressly defined, and money-laundering, terrorism financing and proliferation financing offences are recognised as capable of being carried out through digital systems, encryption technologies and virtual asset platforms.

 

In addition, the introduction of a specific offence targeting, anonymity enhancing virtual asset tools, those designed to obstruct the tracing of transactions or the identification of their parties, further strengthens the regime’s capacity to address technologically enabled concealment.

 

Together, these provisions ensure that virtual asset activities are subject to the same standards of transparency and oversight applied to traditional financial services, positioning the regulatory framework to respond to emerging digital-asset risks with greater clarity.

 

Lower knowledge threshold and strengthened penalties

 

The framework also revises the knowledge standard applied to principal offences, lowering the threshold for establishing awareness of the illicit nature or purpose of funds. For money laundering, terrorism financing and proliferation financing conduct, knowledge may now be inferred from factual and objective circumstances, rather than requiring direct proof of subjective intent. This refinement enables enforcement where risk indicators are ignored or where conduct reflects wilful blindness to the nature of the funds, elevating expectations on both institutions and individuals.

 

Individuals face higher fines and potential imprisonment, while legal persons may be subject to penalties ranging from AED 5 million to AED 100 million or higher, where fines are linked to the value of the criminal property involved. Courts may also order the dissolution of an entity or the closure of premises in serious cases. Proceedings and penalties relating to these offences do not lapse with time, creating enduring exposure. These measures reinforce the need for proactive, risk-sensitive AML controls supported by effective governance.

 

Preventive measures and regulation of VASPs

 

Preventive obligations have been expanded and clarified, particularly with the inclusion of VASPs within the regulated perimeter. Financial institutions, Designated Non-Financial Businesses or Professions (DNFBPs) and VASPs must implement risk-based customer due diligence, verify beneficial ownership, maintain detailed records, implement targeted financial sanctions obligations, and report suspicious transactions to the Financial Intelligence Unit (FIU). Operating without an appropriate licence or registration constitutes an offence.

 

These obligations integrate virtual asset activity into the established compliance landscape and reinforce the expectation that all financial service channels, traditional or digital, apply equivalent standards of scrutiny and control.

 

Strengthened FIU and investigative powers

 

The FIU’s operational authority has been enhanced. It may suspend suspicious transactions for up to ten working days and freeze funds for 30 days without prior notice, with potential extension by the Public Prosecution. Competent authorities may access banking and systems data, impose travel bans, monitor accounts and conduct controlled operations, enabling earlier detection and more coordinated intervention in cases of suspected financial crime.

 

These powers strengthen the investigative infrastructure supporting the AML framework and enable a more agile response to emerging risks.

 

International cooperation and asset recovery framework

 

The New AML Law also enhances the UAE’s ability to cooperate internationally. UAE courts may recognise and enforce foreign provisional measures and confiscation orders without the need for a domestic investigation, and competent authorities are required to prioritise and respond promptly to mutual assistance requests. A forthcoming Cabinet decision will set out procedures for the management and disposal of seized, frozen and confiscated assets, ensuring that asset-recovery efforts are supported by clear operational guidelines.

 

These developments improve the efficiency of cross-border enforcement and reinforce the UAE’s reputation as a cooperative and reliable jurisdiction in the global AML landscape.

 

Conclusion

 

Taken together, these reforms mark a decisive shift in the UAE’s approach to financial-crime risk: expectations on institutions are higher, supervisory powers are broader, and the margin for error is smaller. Businesses operating in or from the UAE, whether in financial services, commercial sectors, professional services, or virtual asset activities, should take this moment to reassess the adequacy of their AML arrangements. In practice, this may require recalibrating risk assessments, strengthening customer due diligence frameworks, enhancing sanctions-screening capabilities and updating escalation protocols to reflect the expanded definitions, lowered knowledge threshold and increased penalties under the New AML Law.

 

Afridi & Angell regularly assists clients in navigating regulatory developments of this nature. Our team advises on the design and implementation of AML compliance frameworks, conducts gap analyses and risk assessments, prepares and updates internal policies and reporting procedures, and provides targeted training for management and frontline staff. We are well positioned to support organisations in aligning their operations with the New AML Law and ensuring they meet evolving regulatory expectations. ■

The UAE’s new banking law: a step forward for financial innovation

On 16 September 2025, Federal Decree-Law 6 of 2025 (the New Banking Law) came into force replacing UAE Federal Decree-Law 14 of 2018. The New Banking Law represents a comprehensive modernisation of the UAE’s financial regulatory framework, expanding the supervisory remit of the Central Bank of the United Arab Emirates (CBUAE) to cover a broader range of financial and (for the first time) extending CBUAE remit to include technology service providers that support the provision of financial services in and from the UAE.

 

Licensed financial activities

 

The New Banking Law broadens the scope of what constitutes regulated financial services, and notably now includes:

 

– so called “open finance services”; and

– payment services using virtual assets.

 

Article 62 of the New Banking Law provides that any person carrying on, offering, or facilitating a licensed financial activity regardless of the technology or platform used is subject to CBUAE licensing. Article 62 therefore covers: (1) virtual assets payment tokens or other digital or physical instruments used in connection with the licensed activities, and (2) digital infrastructure providers, platforms, and decentralised applications that enable access to financial services such as payments, remittances, and investments.

 

The digital dirham and virtual-asset payments

 

The New Banking Law grants the CBUAE clear authority to issue and regulate the digital dirham and confirms its status as legal tender to provide legal certainty around the use of digital money in the UAE.

 

Implications for businesses

 

The New Banking Law significantly expands the regulatory landscape for banks, fintechs, and technology service providers involved in payments, tokenisation, and open finance. Entities operating or planning to operate in these sectors should assess whether their services fall within the CBUAE’s expanded regulatory perimeter. The New Banking Law contemplates a grace period of one year, meaning that businesses that need to adjust their license status to comply with the New Banking Law have till September 2026 to comply.

 

Given the one-year grace period granted under the New Banking Law, businesses are encouraged to begin their internal reviews and prepare for upcoming implementing regulations. Afridi & Angell is well placed to assist with any required internal gap analysis, as well as the licensing process contemplated by the New Banking Law. ■

Pre-action Letters: Dubai International Financial Centre (DIFC)

This Q&A focuses on Dubai International Finance Centre (DIFC) specific information on all the key issues to consider before issuing or responding to a pre-action better. Furthermore, this Q&A provides country-specific commentary on Practice note, Letter before action (Pre-action or demand letter): Cross-border, and forms part of Cross-border dispute resolution.

Real Estate Dispute: Dubai Court of Cassation Clarifies Conditional Contracts and Manager Liability

The Dubai Court of Cassation (DCC) recently issued an important judgment in a real estate dispute, providing clarity on two key legal issues: the effect of suspensive conditions in conditional contracts and the personal liability of managers of limited liability companies (LLCs) in cases of fraud or misconduct.

 

Afridi & Angell acted for the buyer in this case.

 

Facts

 

– The buyer entered into a sale and purchase agreement (SPA) with a Dubai-based LLC (the seller) to purchase an off-plan property in the secondary market.

 

– The terms of the SPA required the buyer to pay nearly half the purchase price as a deposit, and the balance to be paid after the developer hands over the property.

 

– The contract contained additional terms – departing from the standard conditions of the Dubai Real Estate Regulatory Authority (RERA) – allowing the seller to encash the deposit cheques before completion. At the seller’s request, the cheques were addressed in the name of the manager of the seller entity (who was also the sole shareholder).

 

– The developer failed to hand over the property on time. While the buyer remained willing to proceed, the seller withdrew from the transaction and refused to return the deposit paid. Relying on the additional terms, the seller argued it was entitled to withdraw from the transaction and retain the deposit because the buyer was in breach of the contractual payment deadline.

 

– The buyer filed a claim against the seller and its manager, while the seller counterclaimed for damages.

 

Court Findings

 

Conditional Contracts

 

– The court found that completion of the sale was made conditional upon the developer’s handover of the project by a certain date. The court agreed with the buyer’s argument that this condition was a ‘suspensive condition’, and since it was not fulfilled within the contractual deadline, the seller was ordered to return the deposit to the buyer with interest.

 

 

– In appeal, the seller argued that in the context of an off-plan sale of property, delivery or handover of the project does not mean “actual” delivery of the property by the developer, but rather “constructive” delivery (i.e., transfer of title), which meant that the seller was ready to transfer the title to the buyer at all times. The DCC dismissed this ground and confirmed that pursuant to Articles 420 and 425 of the Civil Code, a conditional obligation is one that depends on the occurrence of a future or uncertain event, upon the happening of which, an obligation will either arise or cease. Where the obligation is subject to a suspending condition, it remains unenforceable until the relevant condition materialises or is fulfilled.

 

 

– On that basis, the DCC upheld the finding that the obligations of both parties (buyer to pay the balance and seller to transfer title) fell away as the suspending condition did not occur (i.e., handover of the project by the developer) without attributing a breach to either party. Accordingly, the lower court’s finding was upheld insofar as the deposit ought to be repaid to the buyer with interest. In this respect, the DCC opined that:

 

“A conditional obligation is one that depends upon a future and uncertain event, upon which the obligation either arises or is extinguished. If the condition is suspensive, it has the effect of suspending the enforceability of the obligation until the occurrence of that event upon which it depends.”

 

– The DCC held that the suspensive condition in the SPA has the effect of suspending “the enforceability of the plaintiffs’ obligation to pay the balance of the price until the occurrence of the event upon which it depends, namely the developer’s handover of the unit to the seller. The obligation to pay the balance of the price is deemed to exist during the suspension period but remains unenforceable, as it becomes operative only upon the occurrence of the condition.”

 

Liability of Manager

 

– The buyer sought to hold the seller’s manager personally liable on the basis of fraudulent conduct. The court upheld the buyer’s claim, finding that the manager had acted fraudulently by:

 

– depositing the buyer’s funds into his personal account,

 

– cancelling the seller entity’s trade license and concealing its liquidation during the court proceedings, and

 

– selling the property to a third party.

 

 

– The DCC confirmed that managers of an LLC are not personally liable for the company’s debts, except where fraudulent conduct, deceit, or bad faith is established. On the facts of this case, the DCC found that the manager had acted fraudulently and accordingly upheld the finding of personal liability.

 

Key Takeaways

 

– Suspensive conditions: This case illustrates the Dubai Courts’ approach to the interpretation of conditional contracts and obligations, ensuring that where a suspensive condition is not fulfilled, contracting parties are restored to their original positions. Where a contract is tied to a future event (e.g., project handover), and the event does not occur within the contractual deadline, the contract terminates automatically and any payments made must be returned.

 

– Manager liability: The judgment underscores the courts’ readiness to hold managers personally liable where fraud or misconduct is established. The DCC reaffirmed that, in exceptional cases, company managers can be held personally liable if they act dishonestly or misuse their position. ■

Islamic Finance and Markets Law (UAE chapter), Lexology In-Depth

The United Arab Emirates (UAE) has always provided an attractive environment from which to provide Islamic finance services and products into the Gulf Cooperation Council (GCC) and beyond. In addition to being an established and vibrant global financial centre and having its geographical location in the centre of the Asian and Western financial markets, the UAE also provides a legal system and a judiciary that is familiar with the principles of shariah. This chapter provides an in-depth analysis of everything you need to know about the Islamic finance and markets in the UAE.

The Beginning of the Era of Artificial Intelligence

Artificial Intelligence (AI) has become one of the fastest-growing drivers of global markets, attracting an influx of investment. In the United States, the world’s largest AI hub, funding into AI companies continues to increase as industries from finance to healthcare seek to benefit from its transformative potential.[1]

 

This is not only limited to the U.S., but it is increasingly mirrored in global markets, particularly in the Middle East. Substantial resources are being directed into AI development in the MENA region, with the UAE being at the forefront of these efforts. In 2024, Microsoft and G42, Abu Dhabi’s leading AI technology holding company, announced a $1.5 billion collaboration to promote responsible and secure AI. In addition, the country has implemented long-term strategic frameworks, including the National Artificial Intelligence Strategy 2031 published by the UAE Minister of State for Artificial Intelligence Office, which aims at positioning itself as a global AI hub.

 

In 2023, the United States and the United Arab Emirates signed a joint statement on AI cooperation, reaffirming their shared commitment to advancing “safe, secure, and trustworthy AI.”[2] The agreement highlights a joint effort to align regulatory frameworks, foster ethical research, and create opportunities for trade and investment to develop the AI infrastructure. With shared goals of safe innovation, talent development, and cross-border investment, the agreement positions the UAE as a key driver of AI in the Middle East.

 

The combination of strategic government initiatives, international cooperation, and increasing private and public investment flows suggests that the region is eager to become a major player in the global AI economy.

 

Legal Issues surrounding AI

 

Artificial intelligence is advancing faster than many legal systems can keep up. As countries adopt AI across industries, several legal and regulatory questions have emerged. These challenges are particularly relevant in areas such as ownership rights, data protection, and accountability.

 

Intellectual Property and Ownership

 

A central issue is ownership of AI-generated work. Most legal systems around the world do not allow an AI system to be recognized as an inventor[3]. While the UAE is unclear regarding its position, it is likely that, in practice, it will adopt a similar approach. In this case, developers usually protect their work by claiming copyright over their codes or by keeping their methods private so others cannot copy them. This leaves a practical challenge: while human-created inventions can be formally protected, many AI-created innovations cannot, creating uncertainty for businesses investing heavily in the sector.

 

Data Privacy and Regulation

 

AI relies on vast datasets, making data privacy and regulation critical. To address this, the UAE has established the UAE Council for Artificial Intelligence and Blockchain, a specialised committee tasked with strengthening governance and ensuring effective regulation of AI.[4] These efforts reflect growing recognition that without strong safeguards, AI risks amplifying issues such as existing social biases or exposing sensitive infrastructure to cyberattacks[5]. However, regulatory frameworks are still evolving, the challenge lies in ensuring that innovation does not surpass protection.

 

Liability and Accountability

 

AI’s ability to act autonomously raises many questions regarding accountability. If an AI system in an autonomous vehicle causes an accident, who bears legal responsibility: the developer, the user, or another party?[6] While other regulations governing AI were established in the UAE, regulators have yet to examine AI accountability. This legal gap underscores the complexity of attributing responsibility in AI systems.

 

The Legal and Regulatory Landscape of AI

 

Dubai has chosen a proactive approach and positioned itself as a regional pioneer in regulating and adopting artificial intelligence.

 

Early Strategic Moves

 

The UAE’s 2017 National Artificial Intelligence Strategy laid the groundwork for the country’s development in the AI sector[7]. Dubai has served as a testing ground for implementation with its AI institutions piloting AI applications across healthcare, transport, and government services. By 2017, the UAE Cabinet had established the Council for Artificial Intelligence, chaired by Minister Omar bin Sultan Al Olama, to oversee integration across sectors[8].

 

Free Zone Innovation

 

UAE’s financial free zones, such as the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM), amended their pre-existing regulations, such as the DIFC Data Protection Regulation, to incorporate governance of AI[9]. Both free zones have also developed Financial Technology firms (FinTech)[10][11] that create indirect opportunities for AI start-ups to test new applications in a supervised legal environment.

 

Sector-Specific Regulation[12]

 

Dubai has also taken steps to regulate AI on a sectoral basis:

 

Healthcare – The Ministry of Health and Prevention uses AI in medical fitness exams to detect diseases quickly through X-ray recognition. Hospitals in Abu Dhabi employ AI robots for prescriptions, and Dubai has piloted a fully automated medical fitness centre. These steps show how AI is improving efficiency while supporting public health.

 

Aviation – Emirates Airlines applies AI to optimise flights and passenger services, while Dubai International Airport uses AI for security, logistics, and self-driving ground vehicles. Dubai Customs AI “productivity engine” is expected to save over a million work hours at ports, highlighting AI’s role in efficiency and safety.

 

Transportation – Dubai’s Autonomous Transportation Strategy aims for 25% driverless journeys by 2030. The RTA is testing autonomous vehicles, using AI to monitor customer satisfaction, manage taxis, and regulate parking. Here, regulation seeks to balance innovation with safety and service quality.

 

From the United States to the Middle East, fund flows are being directed into private companies, public markets, and national strategies that place AI at the centre of future growth. For businesses and investors, this signals a future where AI is reshaping the economic landscape of the region.

 

Afridi & Angell advises companies on financing transactions, including venture capital and private equity, as well as mergers & acquisitions. We also advise companies regarding the evolving regulatory landscape in the UAE. ■

 

 

[1] https://www.weforum.org/stories/2024/11/healthcare-health-ai/

[2] https://ae.usembassy.gov/united-states-and-united-arab-emirates-cooperation-on-artificial-intelligence/

[3] Article on Legal Issues Related to the Use of Artificial Intelligence

[4] https://ai.gov.ae/ai_council/

[5] https://www.lexismiddleeast.com/eJournal/2020-05-29_6/

[6] Article on Legal Issues Related to the Use of Artificial Intelligence

[7] https://www.lexismiddleeast.com/pn/UnitedArabEmirates/Artificial_Intelligence/

[8] https://uaecabinet.ae/en/fetch-cab-ministers/his-excellency-omar-bin-sultan-al-olama

[9] https://www.whitecase.com/insight-our-thinking/ai-watch-global-regulatory-tracker-uae

[10] https://www.adgm.com/setting-up/fintech

[11] https://www.difc.com/ecosystem/innovation-hub

[12] https://ai.gov.ae/wp-content/uploads/2020/02/AIGuide_EN_v1-online.pdf