UAE Trends and Developments Contributed by: Sujan Malhotra and Vaidehi Kolhe, Ship Law Sea FZ LLE
issue certificates of insurance directly, aligning UAE- flagged vessels with international standards and sup - porting the expansion of the UAE flag. OPRC 1990 The UAE has acceded to the OPRC 1990 through Federal Decree No 188 of 2022, reinforcing national and international co-operation in responding to oil pollution incidents. The Convention requires states to maintain national response systems and contingency plans, and to provide assistance during major pollu - tion events. SRR The SRR, issued by Circular No 19 of 2023, applies to UAE-flagged vessels and certain non-UAE-flagged vessels calling at UAE ports. The regulation prohib - its ship recycling via beaching and landing methods, requiring recycling in dry docks or equivalent facilities, and imposes extensive obligations relating to hazard - ous materials inventories. The SRR exceeds the standards of the Hong Kong Convention and positions the UAE as a leader in sus - tainable ship recycling, albeit with potentially signifi - cant compliance implications for older vessels and international operators. Maritime Sanctions, Trade Controls and Compliance Risk Heightened global sanctions regimes and trade control measures are increasingly intersecting with maritime operations in the UAE, particularly given the country’s role as a major trading, energy and tranship - ment hub. While UAE law does not mirror all foreign sanctions frameworks, compliance considerations are increasingly influencing maritime disputes, including charterparty performance, vessel employment, insur - ance coverage and enforcement risk. The UAE central bank and the Ministry of Economy’s financial intelligence unit have taken a more proac - tive role in issuing compliance circulars, such as the Guidance for Licensed Financial Institutions on Risks related to Trade-Based Money Laundering and Trans - shipment, especially on dual-use goods, financial transfers and beneficial ownership transparency, and conducting audits on suspicious transactions.
Consequently, UAE-registered companies will face local penalties like banks freezing transactions, insurers withholding coverage and ports demanding deeper documentation for violations of international sanctions, even when such sanctions are not directly implemented under UAE law. From a dispute perspective, sanctions-related issues are beginning to arise in the context of off-hire claims, refusal of port entry, denial of insurance cover, and challenges to payment under letters of credit and charterparty hire. These developments underscore the importance of sanctions screening, contractual safe - guards and early legal assessment, particularly where vessels, cargoes or counterparties have exposure to multiple jurisdictions. Conclusion The UAE’s maritime legal framework is undergoing a profound transformation driven by progressive judi - cial decisions, modernised maritime and corporate legislation, and the incorporation of key international conventions. These developments enhance legal cer - tainty, support effective enforcement, and align the UAE with global best practices in maritime commerce and dispute resolution. Combined with practical regulatory initiatives expect - ed in 2026, including enhanced marine traffic controls and sustainability measures, the UAE is positioning itself as a forward-looking maritime hub that balances commercial sophistication with environmental respon - sibility.
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