On 23 April 2026, KIAP Law Firm and UCL co‑hosted a landmark event titled Dispute Resolution in Dubai: DIAC and DIFC. The session brought experts together to explore the practicalities of working with the Dubai International Arbitration Centre (DIAC) and the Dubai International Financial Centre (DIFC) — two leading venues increasingly sought after by Russian businesses looking to resolve cross‑border disputes.
The event attracted business owners, CEOs, heads of key corporate functions and in‑house counsel: professionals actively seeking effective alternatives to European arbitration institutions and aiming to streamline dispute resolution under current market conditions.
Opening insights: client‑centric arbitration
The meeting was opened by Stepan Sultanov, Partner, Head of International Commercial Arbitration Practice at KIAP, Attorneys at Law. He underscored the critical role of client‑centric service in modern arbitration institutions, highlighting how process management can shape outcomes. Drawing on his track record of representing clients under DIAC rules, Stepan outlined the centre’s distinctive features and elaborated on the advantages it gained after being recognised as a permanent arbitral institution (PAI) in Russia.
Legal frameworks and jurisdictional dynamics
Sergey Levichev, Partner at UCL, then turned to the unique legal regimes of Abu Dhabi Global Market (ADGM) and DIFC — free‑zone jurisdictions with independent court systems. He focused on strategies for obtaining interim relief to support foreign proceedings and mapped out the jurisdictional interplay between UAE courts and DIFC courts. Sergey also shared key judicial stances that have shaped recent case law in this area.
Enforcing foreign awards in the UAE: navigating the landscape
Dr Khaled Ali Alkhadhrami, Co‑Founder of UCL, addressed the complexities of enforcing foreign judgments in the UAE. He emphasised that, in the absence of bilateral treaties, the principle of reciprocity remains the cornerstone. Among the key limitations, he flagged conflicts with Sharia law and UAE public policy. Dr Alkhadhrami further clarified that UAE courts do not enforce foreign orders granting interim relief: instead, applicants must file standalone applications for interim measures before the local courts.
Practical strategies and drafting guidance
In the second part of the session, participants delved into the practical considerations for forum selection in dispute resolution and strategic approaches to jurisdiction when seeking interim relief. To wrap up, Stepan Sultanov and Sergey Levichev offered actionable guidance on drafting arbitration clauses — sharing best practices to help parties secure robust and enforceable dispute resolution mechanisms.
Key takeaways
The event underscored the growing appetite among Russian businesses for DIAC and DIFC as credible alternatives for dispute resolution. By sharing real‑world insights and clear operational guidelines, the experts equipped attendees with practical tools to navigate the evolving landscape. Participants also had the chance to engage directly with seasoned practitioners and address their most pressing questions.
We extend our sincere gratitude to all attendees and look forward to further fruitful collaboration.
