When a dispute involves parties, performance or assets in more than one country, the challenges multiply: which law governs the contract, which law governs the arbitration agreement itself, where the arbitration should be seated, and how the award will ultimately be enforced where the assets actually sit. We handle these questions seamlessly, so a multi-country dispute reaches a single, enforceable conclusion.
The seat determines the supervising court and the law governing the arbitration’s validity; the governing law determines the substantive rights; and the enforcement target — the country where the losing party’s assets are — determines what the award must survive. These three must be aligned, ideally at the contract stage. We advise on that alignment across onshore UAE (Federal Law No. 6 of 2018, as amended), the DIFC and ADGM, and foreign seats.
Seat and governing-law strategy at drafting and at the outset of a dispute.
Conducting multi-jurisdictional references — coordinating evidence, witnesses and experts across borders, under the major institutional rules.
Enforcing foreign awards in the UAE under the New York Convention, before the competent courts.
Enforcing UAE awards abroad, coordinating qualified counsel in the target jurisdiction.
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