2012 Newsletter Q1 ABC Dubai
description
Transcript of 2012 Newsletter Q1 ABC Dubai
IT’S ALL ABOUT
TRADE
The first quarter has been buzzing
with of talk about trade in the
American business community, from
the surge in exports from the US to
the UAE, a 36% increase over the
previous year to the anti-corruption and economic sanctions seminar
presented by an ABC member law firm to the recent event with US
Department of Commerce, Assistant Secretary for Export
Enforcement, David Mills, (co-sponsored by the Dubai Chamber) to
the stunning rise in the UAE’s foreign trade to reach a record above
AED 1 trillion. Recovery and optimism is the talk of the town.
The American Business Council The American Business Council
INSIDE Doing Business in the UAE excerpt Anti-Corruption and Economic Sanctions Compliance:
Facts to protect your company Members’ Calendar
IT’S ALL ABOUT TRADE CONTINUED
The Foreign Trade Division of the US Census Bureau announced that exports from the United States to
the United Arab Emirates reached a record level of $15.89 billion in 2011, a 36% increase over exports
in 2010 of $11.67 billion. The UAE is once again America’s number one export market in the Middle
East North Africa (MENA) region and a top 20 destination for US goods worldwide. The previous re-
cord for exports from the US to the UAE of $14.4 billion occurred in 2008.
Trade between the US and the UAE also marked a record high of $18.34 billion in 2011. The UAE ex-
ported $2.44 billion worth of goods to the US in 2011, more than twice its export level to the US in
2010 of $1.15 billion.
Rising investment levels in the UAE across multiple economic sectors including manufacturing, avia-
tion and technology drove the export increase from the US. Aircraft, machinery and autos topped the
list of US exports arriving in the UAE in 2011. Goods manufactured in every state were exported to the
UAE, with December as the highest month for exports, totaling $1.824 billion. The top US export to
the UAE in 2011 was transportation equipment at $5.893 billion. Aluminum products are the single
largest export category from the UAE to the US.
According to Justin Siberell, US Consul General Dubai, “American businesses play a key role in the
commercial life of Dubai and the UAE. American companies have for decades encountered a welcom-
ing business climate here and have, as a result developed strong presence in many economic areas.”
As a large and growing market for US companies, the UAE’s policy of economic diversification and its
ideal geographic location continue to strengthen trade links between the two countries.
I. INTRODUCTION
A foreign company may conduct business in the
UAE by operating from "off-shore" (via an agent or
directly with customers), by operating in a "free
zone" and by operating directly in one or more of
the seven Emirates (but outside of a free zone).
There are both federal and Emirate-specific laws
and regulations, and there can be multiple regula-
tory authorities at the federal and Emirate levels.
Also, the discretionary policies, practices and pro-
cedures of these authorities supplement the official
laws and regulations and can affect business to a
great extent. Determining the most appropriate
alternative depends on many factors, including the
targeted customer base and the nature of the prod-
ucts or services to be offered. Set forth below is an
overview of the primary methods for foreign busi-
nesses to conduct business in the UAE, as well as a
summary of several other key considerations for
doing business in the UAE.
Doing Business in
the U.A.E.
This article will be published in the 2012 ABC Directory in its entirety.
It is supplied by ABC President's Club member
The UAE welcomes foreign direct investment by Ameri-can businesses. However, the rules and requirements for doing business in the UAE are complex and often misun-derstood. This overview identifies the different ways to do business in the UAE and points out important consid-erations, including some important US laws and regula-tions that apply to operations here.
Copyright 2012 - Fulbright & Jaworski L.L.P. The foregoing overview is not intended to substitute for legal advice on specific matters.
II. INDIRECT OPERATIONS – DEALING WITH AGENTS
Foreign entities generally may make private sector product
sales from off-shore directly into the UAE without participation
by a UAE party. In addition, UAE companies with foreign own-
ership may import and resell goods upon obtaining the appro-
priate licenses. However, only UAE nationals (or entities wholly
-owned by UAE nationals) may conduct certain "commercial
agency activities" as a registered commercial agent, with its
associated rights and privileges.
The UAE Commercial Agencies Law, Federal Law No. 18 of
1981, as amended by Federal Law No. 14 of 1988, and Federal
Law No. 13 of 2006 (the "2006 Amendments"), and Federal Law
No. 2 of 2010 (the "2010 Amendments") (collectively, the
"Commercial Agency Law"), regulates and governs the appoint-
ment of registered commercial agents, sales representatives
and distributors in the UAE. The Commercial Agency Law is
supplemented by, inter alia, the UAE Commercial Transactions
Law, Federal Law No. 18 of 1993 (the "Commercial Code"), im-
plementing regulations, custom and practice. Together, the
Commercial Agency Law and the Commercial Code provide the
primary regulatory framework for agency relationships through
which foreign businesses provide products and services in the
UAE.
The Commercial Agency Law is a federal law that applies
throughout the UAE and grants registered commercial agents
formidable statutory rights as detailed below. Certain public
sector sales require the involvement of a registered commercial
agent. Otherwise, a foreign company can choose alternative
means of selling into the UAE that do not involve a registered
commercial agent.
A. Registered commercial agents are entitled to
an exclusive territory covering at least one Emirate for the
specified products or services.
B. Unless otherwise agreed, registered commer-
cial agents are entitled to receive commissions on sales in their
designated territory irrespective of whether such sales are
made by or through the commercial agent.
C. Registered commercial agents are entitled to
prevent products subject to their agency from being imported
into the UAE if the commercial agent is not the consignee,
unless the UAE Council of Ministers has exempted the subject
products from application of the Commercial Agency Law. This
potential exemption of designated products was confirmed as
part of the 2006 Amendments. Products currently excluded
from the application of the Commercial Agency Law include the
following foodstuffs and related products: dry and condensed
milk, frozen and canned vegetables, children's foodstuffs, milk,
poultry, cooking oil, rice, flour, fish products, meat and its prod-
ucts, tea, coffee, cheese, pasta (macaroni, vermicelli), sugar
and diapers.
D. A principal may not terminate or fail to renew
the agency agreement unless there is a material reason justify-
ing such termination or non-renewal. Either party is entitled to
claim compensation for damages suffered and losses incurred
due to termination or non-renewal of a registered commercial
agency. In practice, this is a benefit to the commercial agent
only.
Furthermore, commercial agents are not limited to seeking
remedies under the Commercial Agency Law. For example, a
commercial agent might also claim damages for improper ter-
mination or non-renewal pursuant to the Commercial Code.
E. A registered commercial agent can preclude
the foreign principal from appointing a replacement registered
agent even if the registered agency was for a fixed term that
has expired, unless the former agent consents or the principal
obtains a favorable decision from the specialized agency dis-
putes committee or a court in the UAE.
In addition, the Commercial Agency Law provides that commer-
cial agency agreements shall be governed exclusively by UAE
law notwithstanding any provision to the contrary in the
agency agreement. Furthermore, UAE Cabinet Resolution No. 3
of 2011 Concerning the Commercial Agencies Committee re-
quires parties to submit their disputes to a specialized agency
disputes committee that has original jurisdiction over disputes
regarding registered commercial agency agreements, including
questions of agency de-registration. The committee may refer
disputes to the UAE courts, and parties may also challenge in
court decisions made by the committee.
According to the Commercial Agency Law, a commercial agent
has to register its agency agreement with the UAE Ministry of
Economy and Commerce (“Ministry of Economy”) to claim the
benefits of the Commercial Agency Law. But there have been
instances where some courts have applied the Commercial
Agency Law to unregistered commercial agency agreements in
certain contexts. The 2006 Amendments had led the interna-
tional business community to expect a trend towards more
liberalization in this area, but, the 2010 Amendments were a
step in the opposite direction and a clear signal of greater, or at
least continued, protectionism for UAE commercial agents.
The statutory protections for commercial agents under the
Commercial Agency Law create an obvious disincentive to for-
eign entities to do business through registered commercial
agencies if alternative means are available. The three most
common alternative means are: (i) to sell directly from over-
seas (i.e., "off-shore") to the end-user customer; (ii) to sell
through an agent other than a registered commercial agent;
and (iii) to establish a direct legal presence in the UAE.
Evaluating statutory protections and other commercial and
legal principles and practices are important not only in negoti-
ating new arrangements with UAE distributors, representatives
and agents, but also in ending any such relationships. Invaria-
bly, termination of agency relationships is contentious, time
consuming and expensive, even if the agent is not a registered
commercial agent.
III. DIRECT OPERATIONS
In addition to a foreign entity establishing an "indirect" busi-
ness presence in the UAE via an agency relationship, there are
several alternatives by which a foreign entity may be licensed
to undertake specified activities on a direct, permanent basis in
the UAE. The UAE Commercial Companies Law, Federal Law
No. 8 of 1984, as amended (the "Companies Law"), provides for
a number of different corporate structures. The primary alter-
natives for foreign entities to establish direct business opera-
tions in the UAE (outside the free zones) are (i) registration of a
branch office and (ii) incorporation of a limited liability com-
pany with a UAE national "partner".
By establishing a direct business presence in the UAE, a foreign
entity is permitted to engage in specified activities as licensed
by the relevant UAE authorities. Except for certain "free zone"
registrations and operations discussed below, entities engaging
in commercial activities in the UAE must be separately regis-
tered and licensed at the federal UAE level (subject to excep-
tions for certain branch offices, e.g., see Section III.A below), as
well as in each Emirate where they wish to operate. Commer-
cial entities must also be registered with, inter alia, the Immi-
gration Department of the UAE Ministry of Interior (the
"Immigration Department") and the UAE Ministry of Labor and Social
Affairs (the "Ministry of Labor") to secure employment/residency visas
(if necessary) and work permits for their personnel.
A. Branch Office
Through registration of a branch office, a foreign entity can
establish, on a wholly owned basis, a direct business presence
to perform specified activities in the Emirate where the branch
is licensed. No UAE participation is required other than utilizing
the services of a UAE national "local agent" to handle certain
administrative matters, as described below. Such a branch of-
fice is not a separate and distinct legal entity from the foreign
company. Rather, the foreign company itself is licensed locally
to undertake specified activities in the UAE through its branch
office. The foreign company is fully responsible for the liabili-
ties of the branch office.
Doing Business in the U.A.E. excerpt from the 2012 ABC membership Directory
II. INDIRECT OPERATIONS – DEALING WITH AGENTS
Foreign entities generally may make private sector product
sales from off-shore directly into the UAE without participation
by a UAE party. In addition, UAE companies with foreign own-
ership may import and resell goods upon obtaining the appro-
priate licenses. However, only UAE nationals (or entities wholly
-owned by UAE nationals) may conduct certain "commercial
agency activities" as a registered commercial agent, with its
associated rights and privileges.
The UAE Commercial Agencies Law, Federal Law No. 18 of
1981, as amended by Federal Law No. 14 of 1988, and Federal
Law No. 13 of 2006 (the "2006 Amendments"), and Federal Law
No. 2 of 2010 (the "2010 Amendments") (collectively, the
"Commercial Agency Law"), regulates and governs the appoint-
ment of registered commercial agents, sales representatives
and distributors in the UAE. The Commercial Agency Law is
supplemented by, inter alia, the UAE Commercial Transactions
Law, Federal Law No. 18 of 1993 (the "Commercial Code"), im-
plementing regulations, custom and practice. Together, the
Commercial Agency Law and the Commercial Code provide the
primary regulatory framework for agency relationships through
which foreign businesses provide products and services in the
UAE.
The Commercial Agency Law is a federal law that applies
throughout the UAE and grants registered commercial agents
formidable statutory rights as detailed below. Certain public
sector sales require the involvement of a registered commercial
agent. Otherwise, a foreign company can choose alternative
means of selling into the UAE that do not involve a registered
commercial agent.
A. Registered commercial agents are entitled to
an exclusive territory covering at least one Emirate for the
specified products or services.
B. Unless otherwise agreed, registered commer-
cial agents are entitled to receive commissions on sales in their
designated territory irrespective of whether such sales are
made by or through the commercial agent.
C. Registered commercial agents are entitled to
prevent products subject to their agency from being imported
into the UAE if the commercial agent is not the consignee,
unless the UAE Council of Ministers has exempted the subject
products from application of the Commercial Agency Law. This
potential exemption of designated products was confirmed as
part of the 2006 Amendments. Products currently excluded
from the application of the Commercial Agency Law include the
following foodstuffs and related products: dry and condensed
milk, frozen and canned vegetables, children's foodstuffs, milk,
poultry, cooking oil, rice, flour, fish products, meat and its prod-
ucts, tea, coffee, cheese, pasta (macaroni, vermicelli), sugar
and diapers.
D. A principal may not terminate or fail to renew
the agency agreement unless there is a material reason justify-
ing such termination or non-renewal. Either party is entitled to
claim compensation for damages suffered and losses incurred
due to termination or non-renewal of a registered commercial
agency. In practice, this is a benefit to the commercial agent
only.
Furthermore, commercial agents are not limited to seeking
remedies under the Commercial Agency Law. For example, a
commercial agent might also claim damages for improper ter-
mination or non-renewal pursuant to the Commercial Code.
E. A registered commercial agent can preclude
the foreign principal from appointing a replacement registered
agent even if the registered agency was for a fixed term that
has expired, unless the former agent consents or the principal
obtains a favorable decision from the specialized agency dis-
putes committee or a court in the UAE.
In addition, the Commercial Agency Law provides that commer-
cial agency agreements shall be governed exclusively by UAE
law notwithstanding any provision to the contrary in the
agency agreement. Furthermore, UAE Cabinet Resolution No. 3
of 2011 Concerning the Commercial Agencies Committee re-
quires parties to submit their disputes to a specialized agency
disputes committee that has original jurisdiction over disputes
regarding registered commercial agency agreements, including
questions of agency de-registration. The committee may refer
disputes to the UAE courts, and parties may also challenge in
court decisions made by the committee.
According to the Commercial Agency Law, a commercial agent
has to register its agency agreement with the UAE Ministry of
Economy and Commerce (“Ministry of Economy”) to claim the
benefits of the Commercial Agency Law. But there have been
instances where some courts have applied the Commercial
Agency Law to unregistered commercial agency agreements in
certain contexts. The 2006 Amendments had led the interna-
tional business community to expect a trend towards more
liberalization in this area, but, the 2010 Amendments were a
step in the opposite direction and a clear signal of greater, or at
least continued, protectionism for UAE commercial agents.
The statutory protections for commercial agents under the
Commercial Agency Law create an obvious disincentive to for-
eign entities to do business through registered commercial
agencies if alternative means are available. The three most
common alternative means are: (i) to sell directly from over-
seas (i.e., "off-shore") to the end-user customer; (ii) to sell
through an agent other than a registered commercial agent;
and (iii) to establish a direct legal presence in the UAE.
Evaluating statutory protections and other commercial and
legal principles and practices are important not only in negoti-
ating new arrangements with UAE distributors, representatives
and agents, but also in ending any such relationships. Invaria-
bly, termination of agency relationships is contentious, time
consuming and expensive, even if the agent is not a registered
commercial agent.
III. DIRECT OPERATIONS
In addition to a foreign entity establishing an "indirect" busi-
ness presence in the UAE via an agency relationship, there are
several alternatives by which a foreign entity may be licensed
to undertake specified activities on a direct, permanent basis in
the UAE. The UAE Commercial Companies Law, Federal Law
No. 8 of 1984, as amended (the "Companies Law"), provides for
a number of different corporate structures. The primary alter-
natives for foreign entities to establish direct business opera-
tions in the UAE (outside the free zones) are (i) registration of a
branch office and (ii) incorporation of a limited liability com-
pany with a UAE national "partner".
By establishing a direct business presence in the UAE, a foreign
entity is permitted to engage in specified activities as licensed
by the relevant UAE authorities. Except for certain "free zone"
registrations and operations discussed below, entities engaging
in commercial activities in the UAE must be separately regis-
tered and licensed at the federal UAE level (subject to excep-
tions for certain branch offices, e.g., see Section III.A below), as
well as in each Emirate where they wish to operate. Commer-
cial entities must also be registered with, inter alia, the Immi-
gration Department of the UAE Ministry of Interior (the
"Immigration Department") and the UAE Ministry of Labor and Social
Affairs (the "Ministry of Labor") to secure employment/residency visas
(if necessary) and work permits for their personnel.
A. Branch Office
Through registration of a branch office, a foreign entity can
establish, on a wholly owned basis, a direct business presence
to perform specified activities in the Emirate where the branch
is licensed. No UAE participation is required other than utilizing
the services of a UAE national "local agent" to handle certain
administrative matters, as described below. Such a branch of-
fice is not a separate and distinct legal entity from the foreign
company. Rather, the foreign company itself is licensed locally
to undertake specified activities in the UAE through its branch
office. The foreign company is fully responsible for the liabili-
ties of the branch office.
A branch office may conduct only those activities specified in its
license. The issuance of licenses to branch offices involves dis-
cretion on the part of the governmental authorities, including
with respect to whether they believe the foreign company is one
they desire to have operating in the UAE and in the applicable
Emirate, and the types and scope of activities they will allow.
A representative office is a type of branch office that is not sup-
posed to engage in sales, services or any other type of commer-
cial activity. Rather, a representative office is only supposed to
act as a liaison or administrative office to promote the com-
pany’s products and services and to facilitate business between
the foreign principal and its customers (or intermediaries).
Some direct contact with customers is permitted, but employees
at a representative office are not authorized to engage in sales
or perform services. The approvals for representative offices
generally can be obtained more quickly and with less govern-
mental scrutiny than for other types of branch offices.
Although exceptions were granted in the past, pursuant to Min-
isterial Resolution No. 377 of 2010 (“Resolution No. 377”)
branch offices may not engage in "trading" activities (i.e., buying
and/or importing for resale in the UAE). Thus, branch offices are
not allowed to engage in trading, but this should not affect trad-
ing licenses previously granted to branch offices.
Resolution No. 377 authorizes free zone entities to form branch
offices in the UAE, subject to satisfying licensing requirements.
Further, under Resolution No. 377 branch offices are not re-
quired to register at the Federal level (i.e., the Ministry of Econ-
omy) to perform a special purpose contract with a government
party in the UAE if the requisite license corresponding to the
contract is obtained from the relevant Emirate licensing author-
ity.
Dubai Law No. 13 of 2011 Regulating Economic Activities in Du-
bai (“Dubai Law No. 13”) also contemplates the possibility of
free zone entities establishing branch offices outside the free
zone in Dubai “proper.” Dubai Law No. 13 also provides that
free zone entities may be authorized to engage in their licensed
activities in Dubai proper, but under certain terms and condi-
tions to be issued by the Executive Council. Such terms and con-
ditions have not yet been clarified. Consequently it remains to
be seen how significantly the law will expand the ability of free
zone entities to operate outside the free zones in Dubai proper.
Under Ministerial Resolution No. 208 of 2011, a foreign com-
pany must deposit a sum of Dhs. 50,000 with the Ministry of
Economy for each branch office to be opened in the UAE. Previ-
ously, foreign companies were required to submit a bank guar-
antee for this amount from a bank operating in the UAE.
According to the Companies Law, a foreign entity is required to
appoint a UAE national "local agent" for its branch office. How-
ever, for certain registrations, such as branches providing ser-
vices to the military or financial services, the relevant special
purpose regulatory authority may choose to serve as a nominal
local agent. This determination is made by the relevant regula-
tory authority on a case by case basis.
The local agent is not permitted to own equity in the branch
office. Similarly, the local agent generally may not interfere in
the substantive management of the branch office, unless other-
wise agreed given that the terms of the agency relationship are
a matter of contract between the parties. In practice, a foreign
entity typically contracts with a local agent to provide specific
administrative services such as communicating with government
departments to process the registration and licensing renewals
for the foreign company, and processing visas and work permits
for its personnel. The level and form of compensation paid to
the local agent varies widely in practice and is a contractual mat-
ter to be agreed between the local agent and the foreign entity.
There is no specific level or form of compensation stated under
UAE law. Some local agents charge a fixed annual fee, while
others charge a percentage of revenue, in which case a cap on
compensation is advisable. As for all foreign intermediaries, US
companies should perform FCPA due diligence on the local
agent candidate.
B. Limited Liability Company
UAE limited liability companies ("LLCs") must have a minimum
of two and a maximum of 50 equity owners and a minimum of
51% equity ownership by UAE nationals (or entities wholly-owned
by UAE nationals). In this summary, we refer to such equity
owners as "partners", but parties commonly use "shareholder"
and "partner" interchangeably. The minimum capitalization
required by the Companies Law for a limited liability company
(e.g., Dhs. 150,000) was abolished in June 2009 pursuant to Fed-
eral Law No. 1 of 2009 on Amending Certain Provisions of Fed-
eral Law No. 8 of 1984 Concerning Commercial Companies. The
current requirement is to have sufficient capital for the busi-
ness, which is to be determined by the partners. However, in
practice, the authorities have discretion to impose their own
requirements (e.g., Dhs. 300,000 in Dubai, and also minimum
capitalization requirements for certain types of activities, such
as industrial and manufacturing operations). As a practical mat-
ter most businesses require a certain amount of capital to oper-
ate, often greater than Dhs. 150,000. Also, there is risk that
having no minimum amount of capital could potentially expose
partners to greater personal liability due to insufficiently capital-
izing the business. In any event, it will take time to assess the
practical impact of eliminating the minimum capitalization re-
quirement for an LLC.
Recent press reports indicate that the UAE Council of Ministers
has approved a new Companies Law that will relax existing for-
eign ownership restrictions (e.g., permit more than 49% foreign
ownership in an LLC), at least for certain sectors, and impose
minimum corporate governance standards. However, as of
early 2012 the new law has not been published in the official
gazette.
Pursuant to the Companies Law, LLCs may be licensed to engage
in a wide range of commercial activities, except for banking, in-
surance and the investment of money for third parties. For ex-
ample, an LLC may engage in trading. An LLC usually is the pre-
ferred vehicle for a joint venture between a foreign party and a
UAE party.
The creation, capitalization, and governance of an LLC is gov-
erned by the Companies Law and by its charter document (e.g.,
Articles or Memorandum of Association), an Arabic language
contract among the LLC partners that is registered with the local
authorities. This charter document usually is supplemented by
other agreements, such as joint venture agreements. The Com-
panies Law gives the partners a great degree of latitude to nego-
tiate the terms for governance of their LLC. But, in the event of
a conflict between any such supplemental agreements and ei-
ther the registered charter document or the Companies Law,
the latter likely will control.
Parties have implemented a variety of measures (some lawful
and some not) trying to ameliorate the limitations on foreign
ownership of LLCs imposed by the Companies Law. Although
the Companies Law requires at least 51% of the capital of an LLC
to be owned by UAE nationals, it also permits profits and losses
to be split by the LLC partners as they may agree. The various
Emirate licensing authorities impose restrictions in practice, of-
ten limiting to 80% the profits allocable to the foreign partners.
Some foreign parties have tried to engage UAE nationals to par-
ticipate in LLCs as mere "sponsors" or "nominees" (often re-
ferred to colloquially as "silent" or "sleeping" partners) solely for
the sake of appearing to satisfy the UAE national ownership re-
quirements imposed by the Companies Law. Such arrange-
ments typically commit the UAE national to relinquish all profits,
voting rights and other rights of ownership to the foreign party,
often by a "side agreement" not reflected in the registered char-
tered document. Such arrangements are not legal under the
Companies Law, and are criminal violations under Federal Law
No. 17 of 2004 on Combating of Commercial Concealment
(the "Commercial Concealment Law"), which proscribes such
arrangements and imposes stringent penalties on the UAE na-
tional "concealing party" as well as the foreign "concealed
party". Enforcement of the Commercial Concealment Law,
which originally was to be effective in November 2007, was de-
ferred until December 31, 2009 by UAE Cabinet Resolution No.
229/12 of 2007. We are not aware of any subsequent law or
resolution deferring the implementation of the Commercial Con-
cealment Law or issuance of any implementing regulations.
Thus, it would be advisable to assume that the Commercial Con-
cealment Law took effect as of January 1, 2010, although there
have not been reports of active public enforcement of that law.
Even if the authorities choose not to prosecute violators, foreign
parties need to understand that reliance on the types of ar-
rangements described above may be misplaced due to serious
questions about their enforceability and the potential account-
ing and disclosure complications related to securities matters for
the foreign partner and merger and acquisition activity relating
to the LLC.
Doing Business in the U.A.E. excerpt from the 2012 ABC membership Directory
A branch office may conduct only those activities specified in its
license. The issuance of licenses to branch offices involves dis-
cretion on the part of the governmental authorities, including
with respect to whether they believe the foreign company is one
they desire to have operating in the UAE and in the applicable
Emirate, and the types and scope of activities they will allow.
A representative office is a type of branch office that is not sup-
posed to engage in sales, services or any other type of commer-
cial activity. Rather, a representative office is only supposed to
act as a liaison or administrative office to promote the com-
pany’s products and services and to facilitate business between
the foreign principal and its customers (or intermediaries).
Some direct contact with customers is permitted, but employees
at a representative office are not authorized to engage in sales
or perform services. The approvals for representative offices
generally can be obtained more quickly and with less govern-
mental scrutiny than for other types of branch offices.
Although exceptions were granted in the past, pursuant to Min-
isterial Resolution No. 377 of 2010 (“Resolution No. 377”)
branch offices may not engage in "trading" activities (i.e., buying
and/or importing for resale in the UAE). Thus, branch offices are
not allowed to engage in trading, but this should not affect trad-
ing licenses previously granted to branch offices.
Resolution No. 377 authorizes free zone entities to form branch
offices in the UAE, subject to satisfying licensing requirements.
Further, under Resolution No. 377 branch offices are not re-
quired to register at the Federal level (i.e., the Ministry of Econ-
omy) to perform a special purpose contract with a government
party in the UAE if the requisite license corresponding to the
contract is obtained from the relevant Emirate licensing author-
ity.
Dubai Law No. 13 of 2011 Regulating Economic Activities in Du-
bai (“Dubai Law No. 13”) also contemplates the possibility of
free zone entities establishing branch offices outside the free
zone in Dubai “proper.” Dubai Law No. 13 also provides that
free zone entities may be authorized to engage in their licensed
activities in Dubai proper, but under certain terms and condi-
tions to be issued by the Executive Council. Such terms and con-
ditions have not yet been clarified. Consequently it remains to
be seen how significantly the law will expand the ability of free
zone entities to operate outside the free zones in Dubai proper.
Under Ministerial Resolution No. 208 of 2011, a foreign com-
pany must deposit a sum of Dhs. 50,000 with the Ministry of
Economy for each branch office to be opened in the UAE. Previ-
ously, foreign companies were required to submit a bank guar-
antee for this amount from a bank operating in the UAE.
According to the Companies Law, a foreign entity is required to
appoint a UAE national "local agent" for its branch office. How-
ever, for certain registrations, such as branches providing ser-
vices to the military or financial services, the relevant special
purpose regulatory authority may choose to serve as a nominal
local agent. This determination is made by the relevant regula-
tory authority on a case by case basis.
The local agent is not permitted to own equity in the branch
office. Similarly, the local agent generally may not interfere in
the substantive management of the branch office, unless other-
wise agreed given that the terms of the agency relationship are
a matter of contract between the parties. In practice, a foreign
entity typically contracts with a local agent to provide specific
administrative services such as communicating with government
departments to process the registration and licensing renewals
for the foreign company, and processing visas and work permits
for its personnel. The level and form of compensation paid to
the local agent varies widely in practice and is a contractual mat-
ter to be agreed between the local agent and the foreign entity.
There is no specific level or form of compensation stated under
UAE law. Some local agents charge a fixed annual fee, while
others charge a percentage of revenue, in which case a cap on
compensation is advisable. As for all foreign intermediaries, US
companies should perform FCPA due diligence on the local
agent candidate.
B. Limited Liability Company
UAE limited liability companies ("LLCs") must have a minimum
of two and a maximum of 50 equity owners and a minimum of
51% equity ownership by UAE nationals (or entities wholly-owned
by UAE nationals). In this summary, we refer to such equity
owners as "partners", but parties commonly use "shareholder"
and "partner" interchangeably. The minimum capitalization
required by the Companies Law for a limited liability company
(e.g., Dhs. 150,000) was abolished in June 2009 pursuant to Fed-
eral Law No. 1 of 2009 on Amending Certain Provisions of Fed-
eral Law No. 8 of 1984 Concerning Commercial Companies. The
current requirement is to have sufficient capital for the busi-
ness, which is to be determined by the partners. However, in
practice, the authorities have discretion to impose their own
requirements (e.g., Dhs. 300,000 in Dubai, and also minimum
capitalization requirements for certain types of activities, such
as industrial and manufacturing operations). As a practical mat-
ter most businesses require a certain amount of capital to oper-
ate, often greater than Dhs. 150,000. Also, there is risk that
having no minimum amount of capital could potentially expose
partners to greater personal liability due to insufficiently capital-
izing the business. In any event, it will take time to assess the
practical impact of eliminating the minimum capitalization re-
quirement for an LLC.
Recent press reports indicate that the UAE Council of Ministers
has approved a new Companies Law that will relax existing for-
eign ownership restrictions (e.g., permit more than 49% foreign
ownership in an LLC), at least for certain sectors, and impose
minimum corporate governance standards. However, as of
early 2012 the new law has not been published in the official
gazette.
Pursuant to the Companies Law, LLCs may be licensed to engage
in a wide range of commercial activities, except for banking, in-
surance and the investment of money for third parties. For ex-
ample, an LLC may engage in trading. An LLC usually is the pre-
ferred vehicle for a joint venture between a foreign party and a
UAE party.
The creation, capitalization, and governance of an LLC is gov-
erned by the Companies Law and by its charter document (e.g.,
Articles or Memorandum of Association), an Arabic language
contract among the LLC partners that is registered with the local
authorities. This charter document usually is supplemented by
other agreements, such as joint venture agreements. The Com-
panies Law gives the partners a great degree of latitude to nego-
tiate the terms for governance of their LLC. But, in the event of
a conflict between any such supplemental agreements and ei-
ther the registered charter document or the Companies Law,
the latter likely will control.
Parties have implemented a variety of measures (some lawful
and some not) trying to ameliorate the limitations on foreign
ownership of LLCs imposed by the Companies Law. Although
the Companies Law requires at least 51% of the capital of an LLC
to be owned by UAE nationals, it also permits profits and losses
to be split by the LLC partners as they may agree. The various
Emirate licensing authorities impose restrictions in practice, of-
ten limiting to 80% the profits allocable to the foreign partners.
Some foreign parties have tried to engage UAE nationals to par-
ticipate in LLCs as mere "sponsors" or "nominees" (often re-
ferred to colloquially as "silent" or "sleeping" partners) solely for
the sake of appearing to satisfy the UAE national ownership re-
quirements imposed by the Companies Law. Such arrange-
ments typically commit the UAE national to relinquish all profits,
voting rights and other rights of ownership to the foreign party,
often by a "side agreement" not reflected in the registered char-
tered document. Such arrangements are not legal under the
Companies Law, and are criminal violations under Federal Law
No. 17 of 2004 on Combating of Commercial Concealment
(the "Commercial Concealment Law"), which proscribes such
arrangements and imposes stringent penalties on the UAE na-
tional "concealing party" as well as the foreign "concealed
party". Enforcement of the Commercial Concealment Law,
which originally was to be effective in November 2007, was de-
ferred until December 31, 2009 by UAE Cabinet Resolution No.
229/12 of 2007. We are not aware of any subsequent law or
resolution deferring the implementation of the Commercial Con-
cealment Law or issuance of any implementing regulations.
Thus, it would be advisable to assume that the Commercial Con-
cealment Law took effect as of January 1, 2010, although there
have not been reports of active public enforcement of that law.
Even if the authorities choose not to prosecute violators, foreign
parties need to understand that reliance on the types of ar-
rangements described above may be misplaced due to serious
questions about their enforceability and the potential account-
ing and disclosure complications related to securities matters for
the foreign partner and merger and acquisition activity relating
to the LLC.
IV. OPERATION IN A UAE "FREE ZONE"
UAE free zones present a means to conduct business within the
territory of the UAE, but not within its import and customs
boundaries. Such free zones tend to be more "user-friendly"
and conducive to foreign investment than in the UAE proper.
For example, the relevant documents to establish and conduct
business in a free zone are in English. Early free zones included
the Jebel Ali Free Zone ("JAFZ"), which is a seaport and industrial
facility, and the Dubai Airport Free Zone ("DAFZ") at the Dubai
airport. UAE free zones account for a significant portion of for-
eign commercial activity in the UAE. These free zones have
been instrumental in positioning the UAE as the commercial hub
of the Arabian Gulf and as a leading international trans-
shipment center.
Each free zone has its own special purpose business regulatory
schemes, but the rules and practices for business activities are
quite similar from zone to zone. Among the investment incen-
tives generally available in the free zones are 100% foreign own-
ership, guaranteed income tax holidays and no restrictions on
repatriation of capital and profits. Moreover, as the names im-
ply, there generally are no customs or other import duties or
taxes with respect to imports into or exports out of the various
free zones, provided that goods are not then imported into the
UAE proper.
Free zones generally permit: (i) the registration of wholly-
owned branch offices of foreign companies; or (ii) the incorpora-
tion of single or multiple shareholder corporate entities with
100% foreign ownership. The types of activities usually permit-
ted in the various free zones are trading, industrial, and service
activities, although there are some exceptions.
Some free zones follow the economic cluster model focusing on
particular types of industries or services, such as: (i) Dubai Tech-
nology and Media Free Zone ("TECOM," which includes Dubai
Internet City, Dubai Media City, Dubai Knowledge Village, Dubai
International Academic City, Dubai Healthcare City and others);
(ii) Dubai International Financial Centre ("DIFC"); (iii) Dubai Multi
Commodities Centre and Jumeirah Lakes Towers; and (iv) Dubai
Silicon Oasis. It is important to note that free zone registrants
may not engage in business in the UAE proper absent independ-
ent licensing or some other legal arrangement permitting the
specific business activities outside the free zone. However, em-
ployees working for a free zone branch or company may live
anywhere in the UAE.
Other Emirates also have established free zones. Sharjah has a
seaport free zone (Hamriyah Free Zone) and an airport free zone
(Sharjah Airport International Free Zone). Ras Al Khaimah, Fu-
jairah, Ajman and Umm Al Quwain also have free zones. Abu
Dhabi has only recently begun to establish free zones. Abu
Dhabi has a media free zone called Twofour54, Masdar City,
which is intended to become a leading global centre for renew-
able energy research, development, implementation and invest-
ment, and Abu Dhabi Airports Company Skycity which operates
Abu Dhabi Airport Free Zones at the three main airports in Abu
Dhabi. In addition, Abu Dhabi has set up ZonesCorp to establish,
manage and operate specialized economic zones within Abu
Dhabi.
There is a wealth of information available on the Internet about
the various free zones in the UAE.
V. OTHER KEY CONSIDERATIONS
A. Monetary Policies
There are currently no foreign exchange control laws or other
legal restrictions on the repatriation of capital and earnings.
Currently, the UAE Dirham is pegged to the US Dollar and the
exchange rate has been approximately US $1 = UAE Dirhams
3.67 for many years.
The UAE Central Bank has adopted money laundering regula-
tions that impose certain restrictions, including reporting obliga-
tions on certain cash transactions. In addition, the Dubai Finan-
cial Services Authority acts as an independent regulator for cer-
tain entities that are registered in the DIFC.
B. Taxes
There are no special purpose income tax laws or regulations,
corporate or individual, issued at the UAE federal level. At the
local Emirate level, most of the Emirates have issued corporate
income tax decrees in some form. However, to date such tax
decrees have not been enforced and income taxes generally
have not been imposed by any of the Emirates except with re-
spect to: (i) certain companies engaged in the production of oil,
gas and/or petrochemicals; and (ii) foreign bank branches. Also,
currently there are no personal income tax laws enacted in any
of the Emirates.
There are also no withholding taxes, no payroll taxes, and no
value-added taxes or sales taxes, except with respect to certain
items such as alcohol and tobacco. But government authorities
may be seeking additional sources of revenue. As described in
Section V(F) below under Labor and Employment, the govern-
ment is now collecting payroll data that would enable it to im-
plement a payroll tax. Also, it has been rumored that a VAT will
be implemented in the future, but no developments in this re-
gard have occurred as of early 2012. There are taxes on items
such as services at hotels, as well as residential and commercial
premises leases (e.g., annual fees collected based on the value
of a lease).
Persons subject to tax in other jurisdictions, such as persons
subject to US tax on worldwide income, should consult their tax
advisors regarding the application of such taxes to their activi-
ties in the UAE. The UAE has entered into tax treaties with a
number of countries.
C. Intellectual Property
There are three primary federal laws related to the protection of
intellectual property rights in the UAE, namely: (i) the UAE Trade-
mark Law, Federal Law No. 8 of 2002, which amended Federal Law
No. 37 of 1992; (ii) the UAE Copyright Law, Federal Law No. 7 of
2002; and (iii) the UAE Patent Law, Federal Law No. 17 of 2002.
These primary intellectual property laws are supplemented by other
legislation, including Federal Law No. 4 of 1979 Regarding the Pre-
vention of Fraud and Deception in Commercial Transactions, the
Commercial Code, and various ministerial resolutions. In addition,
it is important to note that the UAE is a member of many interna-
tional treaties, including treaties related to intellectual property
such as the Berne Convention. Also of interest, the UAE has a fed-
eral consumer protection law, Federal Law No. 24 of 2006 Concern-
ing the Protection of Consumers. Various e-commerce related laws
have also been implemented at the federal level as well as within
several individual Emirates.
D. Real Estate
As is the case in many Middle East countries, real property is
afforded special "guarded" status in the UAE. Although the UAE
Constitution vests legislative authority over real estate owner-
ship with the UAE federal government, to date no UAE federal
real estate law has been passed. Federal Law No. 5 of 1985 Re-
garding the Civil Transactions Law (the "Civil Code") includes
provisions relating to real estate, but not with respect to fee
ownership. Thus, land ownership restrictions in the UAE are
generally established by rules and practices on an Emirate-by-
Emirate basis. In particular, each Emirate maintains its own poli-
cies and practices with respect to land ownership by non-UAE
nationals. In this regard, there have been significant legislative
and practice developments in nearly all of the Emirates. These
developments are expected to continue for real estate matters
throughout the UAE. The following provides only a brief over-
view of the landscape in Dubai and Abu Dhabi.
Look for the complete article in the 2012 ABC Membership
Directory, with topics including:
Dubai Freehold Property
Abu Dhabi Freehold Property
General Freehold Property Issues
Tenancy Issues
Financial Records and Accounting
Labor and Employment
Immigration
US and Other Regulatory Issues
Export Controls and Sanctions
Anti-Corruption
US Anti-boycott Regulations
Reporting Financial Accounts
Dispute Resolution
Choice of Foreign Law and Venue
Enforcement of Foreign Court Judgments
Enforcement Of Domestic And Foreign Arbitra-
tion Awards
DIFC Courts Expanded Jurisdiction
Personal Conduct
Doing Business in the U.A.E. excerpt from the 2012 ABC membership Directory
IV. OPERATION IN A UAE "FREE ZONE"
UAE free zones present a means to conduct business within the
territory of the UAE, but not within its import and customs
boundaries. Such free zones tend to be more "user-friendly"
and conducive to foreign investment than in the UAE proper.
For example, the relevant documents to establish and conduct
business in a free zone are in English. Early free zones included
the Jebel Ali Free Zone ("JAFZ"), which is a seaport and industrial
facility, and the Dubai Airport Free Zone ("DAFZ") at the Dubai
airport. UAE free zones account for a significant portion of for-
eign commercial activity in the UAE. These free zones have
been instrumental in positioning the UAE as the commercial hub
of the Arabian Gulf and as a leading international trans-
shipment center.
Each free zone has its own special purpose business regulatory
schemes, but the rules and practices for business activities are
quite similar from zone to zone. Among the investment incen-
tives generally available in the free zones are 100% foreign own-
ership, guaranteed income tax holidays and no restrictions on
repatriation of capital and profits. Moreover, as the names im-
ply, there generally are no customs or other import duties or
taxes with respect to imports into or exports out of the various
free zones, provided that goods are not then imported into the
UAE proper.
Free zones generally permit: (i) the registration of wholly-
owned branch offices of foreign companies; or (ii) the incorpora-
tion of single or multiple shareholder corporate entities with
100% foreign ownership. The types of activities usually permit-
ted in the various free zones are trading, industrial, and service
activities, although there are some exceptions.
Some free zones follow the economic cluster model focusing on
particular types of industries or services, such as: (i) Dubai Tech-
nology and Media Free Zone ("TECOM," which includes Dubai
Internet City, Dubai Media City, Dubai Knowledge Village, Dubai
International Academic City, Dubai Healthcare City and others);
(ii) Dubai International Financial Centre ("DIFC"); (iii) Dubai Multi
Commodities Centre and Jumeirah Lakes Towers; and (iv) Dubai
Silicon Oasis. It is important to note that free zone registrants
may not engage in business in the UAE proper absent independ-
ent licensing or some other legal arrangement permitting the
specific business activities outside the free zone. However, em-
ployees working for a free zone branch or company may live
anywhere in the UAE.
Other Emirates also have established free zones. Sharjah has a
seaport free zone (Hamriyah Free Zone) and an airport free zone
(Sharjah Airport International Free Zone). Ras Al Khaimah, Fu-
jairah, Ajman and Umm Al Quwain also have free zones. Abu
Dhabi has only recently begun to establish free zones. Abu
Dhabi has a media free zone called Twofour54, Masdar City,
which is intended to become a leading global centre for renew-
able energy research, development, implementation and invest-
ment, and Abu Dhabi Airports Company Skycity which operates
Abu Dhabi Airport Free Zones at the three main airports in Abu
Dhabi. In addition, Abu Dhabi has set up ZonesCorp to establish,
manage and operate specialized economic zones within Abu
Dhabi.
There is a wealth of information available on the Internet about
the various free zones in the UAE.
V. OTHER KEY CONSIDERATIONS
A. Monetary Policies
There are currently no foreign exchange control laws or other
legal restrictions on the repatriation of capital and earnings.
Currently, the UAE Dirham is pegged to the US Dollar and the
exchange rate has been approximately US $1 = UAE Dirhams
3.67 for many years.
The UAE Central Bank has adopted money laundering regula-
tions that impose certain restrictions, including reporting obliga-
tions on certain cash transactions. In addition, the Dubai Finan-
cial Services Authority acts as an independent regulator for cer-
tain entities that are registered in the DIFC.
B. Taxes
There are no special purpose income tax laws or regulations,
corporate or individual, issued at the UAE federal level. At the
local Emirate level, most of the Emirates have issued corporate
income tax decrees in some form. However, to date such tax
decrees have not been enforced and income taxes generally
have not been imposed by any of the Emirates except with re-
spect to: (i) certain companies engaged in the production of oil,
gas and/or petrochemicals; and (ii) foreign bank branches. Also,
currently there are no personal income tax laws enacted in any
of the Emirates.
There are also no withholding taxes, no payroll taxes, and no
value-added taxes or sales taxes, except with respect to certain
items such as alcohol and tobacco. But government authorities
may be seeking additional sources of revenue. As described in
Section V(F) below under Labor and Employment, the govern-
ment is now collecting payroll data that would enable it to im-
plement a payroll tax. Also, it has been rumored that a VAT will
be implemented in the future, but no developments in this re-
gard have occurred as of early 2012. There are taxes on items
such as services at hotels, as well as residential and commercial
premises leases (e.g., annual fees collected based on the value
of a lease).
Persons subject to tax in other jurisdictions, such as persons
subject to US tax on worldwide income, should consult their tax
advisors regarding the application of such taxes to their activi-
ties in the UAE. The UAE has entered into tax treaties with a
number of countries.
C. Intellectual Property
There are three primary federal laws related to the protection of
intellectual property rights in the UAE, namely: (i) the UAE Trade-
mark Law, Federal Law No. 8 of 2002, which amended Federal Law
No. 37 of 1992; (ii) the UAE Copyright Law, Federal Law No. 7 of
2002; and (iii) the UAE Patent Law, Federal Law No. 17 of 2002.
These primary intellectual property laws are supplemented by other
legislation, including Federal Law No. 4 of 1979 Regarding the Pre-
vention of Fraud and Deception in Commercial Transactions, the
Commercial Code, and various ministerial resolutions. In addition,
it is important to note that the UAE is a member of many interna-
tional treaties, including treaties related to intellectual property
such as the Berne Convention. Also of interest, the UAE has a fed-
eral consumer protection law, Federal Law No. 24 of 2006 Concern-
ing the Protection of Consumers. Various e-commerce related laws
have also been implemented at the federal level as well as within
several individual Emirates.
D. Real Estate
As is the case in many Middle East countries, real property is
afforded special "guarded" status in the UAE. Although the UAE
Constitution vests legislative authority over real estate owner-
ship with the UAE federal government, to date no UAE federal
real estate law has been passed. Federal Law No. 5 of 1985 Re-
garding the Civil Transactions Law (the "Civil Code") includes
provisions relating to real estate, but not with respect to fee
ownership. Thus, land ownership restrictions in the UAE are
generally established by rules and practices on an Emirate-by-
Emirate basis. In particular, each Emirate maintains its own poli-
cies and practices with respect to land ownership by non-UAE
nationals. In this regard, there have been significant legislative
and practice developments in nearly all of the Emirates. These
developments are expected to continue for real estate matters
throughout the UAE. The following provides only a brief over-
view of the landscape in Dubai and Abu Dhabi.
Look for the complete article in the 2012 ABC Membership
Directory, with topics including:
Dubai Freehold Property
Abu Dhabi Freehold Property
General Freehold Property Issues
Tenancy Issues
Financial Records and Accounting
Labor and Employment
Immigration
US and Other Regulatory Issues
Export Controls and Sanctions
Anti-Corruption
US Anti-boycott Regulations
Reporting Financial Accounts
Dispute Resolution
Choice of Foreign Law and Venue
Enforcement of Foreign Court Judgments
Enforcement Of Domestic And Foreign Arbitra-
tion Awards
DIFC Courts Expanded Jurisdiction
Personal Conduct
On March 28, the ABC in partnership with member law
firm Chadbourne & Parke, held a seminar on interna-
tional anti-corruption law and economic sanctions
compliance at The Palace Hotel
in Dubai.
The seminar was attended primarily by ABC members
as well as guests from local and foreign companies,
banks, financial institutions and leading law firms and
provided insight and analysis regarding the implica-
tions of the U.S. Foreign Corrupt Practices Act (FCPA),
the UK Bribery Act, economic sanctions and anti-
money laundering regulations in the U.A.E.
Anti-corruption and Economic
Sanctions Compliance: Learning the facts to protect your company
Chadbourne's MENA practice draws upon
the combined experience of lawyers in
the corporate, litigation, securities, pro-
ject finance, energy, tax, intellectual prop-
erty, real estate, employment law and
trusts and estates areas. In addition to
offices in London, Dubai and Istanbul,
Chadbourne serves clients in the region
through strong relationships with local
law firms in Lebanon, Kuwait, Saudi Ara-
bia, Bahrain, Oman, Qatar, Jordan, Egypt,
Tunisia and Morocco.
Seminar presented by ABC member law firm, Chadbourne & Parke,
examined the relevance of U.S. anti-corruption laws and sanctions for U.S.
and non-U.S. corporations and individuals
The seminar is one of a series on anti-corruption and economic sanctions presented in Istanbul and
Beirut by Chadbourne’s Dubai associate Ramsey Jurdi (and ABC board member) and Scott Peeler,
Chadbourne New York partner in response to the fast expanding needs of corporations in the region.
"Exciting developments are taking place in the U.A.E. and the Middle East," said Chadbourne partner
Scott Peeler. "In particular, foreign companies doing business in the Middle East are facing tougher
scrutiny and penalties than ever before. Companies and their employees and managers need to fully
appreciate the risk of non-compliance, and must implement the strictest anti-corruption controls
where they are needed."
"Anti-corruption laws and economic sanctions are important topics in the region," added Jack
Greenwald, head of Chadbourne's Dubai office. "The seminar in Dubai provided the members of the
ABC the opportunity to obtain important information and to benefit from Chadbourne's experience
and expertise in these fields."
Anti-corruption and Economic
Sanctions Compliance: Learning the facts to protect your company
Speakers, Scott Peeler, left photo, and Ramsey Jurdi, right
photo, give the facts on anti-corruption and sanctions com-
pliance.
MEMBERS’ CALENDAR
Don’t miss a great day of golf
on Dubai’s premiere course
Dubai Creek Golf & Yacht Club
April 21 The 21st Annual ABC Golf Tournament
Driven by
For details and to reserve your place go to our online calendar at
www.abcdubai.com
ABC is on the move!
Watch for exact details of the transition in the coming
weeks, but our offices will be moving to
The Emarat Atrium Building Sheikh Zayed Road
MEMBERS’ CALENDAR
SAVE THE DATE
The ABC Business Forum
May 8, 2012
Join us as we investigate the following business sectors with a view to
producing relevant white paper on ways to increase
opportunities for American Business.
* Healthcare & Insurance * Banking & Finance * Hospitality, Travel, & Tourism * Real Estate
Transportation *Education * Engineering, Construction, & Project Management * Legal Affairs
* Energy * Technology
MEMBERS’ NEWS
Tom Friedman and The Middle East’s Role on the New Silk Road
IHT Global Conversation: Dubai
May 2nd, 2012
Armani Hotel
To celebrate its 125th Anniversary, the International Herald Tribune is convening “The
Global Conversation,” a series of events bringing together high profile speakers and
IHT journalists for an evening of dinner and thought-provoking debate. Join us in Du-
bai, and hear The New York Times’ Foreign Affairs Correspondent Thomas Friedman
discuss whether the Middle East can focus on new economic opportunities through
this period of regional political upheaval, while patterns of global trade and capital
flows are changing dramatically.
Special discount for members code GCDAB
Visit
https://www.eiseverywhere.com/39008?discountcode=GCDAB
for more information or to register.