English law in the financial free zones of the United Arab Emirates
David Russell QC and Gabor Bognar have co-authored an article published in Trusts & Trustees, a leading international journal on trust law and practice.
The article addresses the way in which English law is applied in the two financial free zones of the United Arab Emirates, the Abu Dhabi Global Market (‘ADGM’) and the Dubai International Financial Centre (‘DIFC’).
Each jurisdiction has enacted legislation covering this issue. However, different means of achieving the objective have been chosen.
The ADGM has adopted the common law of England on an ambulatory basis, but English statute law only to a limited extent and at a fixed date.
In contrast, the DIFC has adopted the law of England as a general backstop.
In this article, the differences between these two approaches are set out and their consequences are analysed.
The full text of the article is accessible here.
Barristers: David Russell QC | Gabor Bognar