Practice · Sanctions, Maritime & War-Risk

The UAE is the neutral hub. We are the local counsel.

OFAC, OFSI, EU and UAE sanctions advisory. Red Sea Houthi shipping disputes. Force majeure on commodity supply contracts. War-risk insurance and reinsurance. Dark-fleet and sanctioned-vessel matters. Reconstruction trade for Yemen, Syria, Iraq, Lebanon. The legal work that exists because the UAE sits between everyone else.

Brief us in confidence → Jump to a topic
2021
UAE Federal Decree-Law 26 — sanctions implementation
L.5/1985
Civil Code — force majeure (Art. 273, 893) + hardship (Art. 249)
3rd
Largest container port in the world (Jebel Ali)
$1T+
Annual UAE-routed trade flows

Contents

What we cover

Section I · Sanctions advisory

1. The UAE-side practical view of OFAC, OFSI, EU, UN and UAE sanctions

We are not a US or UK sanctions firm — and we don't pretend to be. What we are is the practical UAE-side counsel that translates the lead-counsel advice from Sullivan & Cromwell, Steptoe, Clifford Chance or your in-house compliance into the UAE contracting, payment-routing, and dispute-resolution implications. Our work covers:

2. Counterparty and end-user screening

We design counterparty-screening protocols for UAE traders, banks and corporates — calibrated to the regulatory exposure profile of the business. The screening framework typically includes: pre-engagement KYC and beneficial-ownership tracing, sanctions-list screening against US/UK/EU/UN/UAE lists, ongoing monitoring with re-screening triggers (M&A, listing change, sanctions update), and contemporaneous documentation that supports a defensible compliance posture if regulators or counterparties later challenge the engagement.

3. Payment-routing structures

One of the most consequential practical questions for UAE businesses with cross-border counterparty exposure is: how do we structure payments to comply with US, UK, EU and UAE sanctions while still getting paid? We advise on payment-routing architecture, currency choice (USD vs EUR vs AED vs CHF vs CNY), corresponding-bank availability, and payment-rail selection (correspondent banking vs CHIPS vs CHAPS vs alternative networks).

Section II · Maritime & shipping

4. Red Sea / Houthi-affected shipping disputes

Since late 2023, Houthi attacks on commercial shipping in the Red Sea and the Bab-el-Mandeb strait have generated one of the most active commercial-dispute segments in the region. Common claim types we handle:

Most matters are arbitrated in London (LMAA), Singapore (SCMA) or DIAC. We act as UAE-side counsel and as lead counsel for UAE-domiciled charterers, owners, traders and insureds.

5. Charterparty & COA disputes

Beyond Red Sea-specific matters, UAE-domiciled shipowners, charterers and traders face the full range of dry-bulk and tanker dispute work — voyage-charter disputes (laytime, demurrage, dispatch), time-charter disputes (off-hire, performance claims, redelivery condition), COA disputes, bill-of-lading disputes, ship-finance enforcement, and Liens. We act under English-law BIMCO standard forms and ad-hoc bespoke contracts.

6. Cargo and war-risk insurance disputes

Cargo and war-risk insurance disputes have been one of the most active sub-segments since 2022. We advise insureds, insurers and brokers on coverage scope, war-risk versus marine policy boundaries, named-perils interpretation, subrogation, salvage, general average, and the increasingly contested question of whether specific incidents (Red Sea attacks, Russia-Ukraine cargo losses) fall within "act of war" exclusions or war-risk specials.

7. Sanctioned-vessel and dark-fleet matters

We act on the lawful side of sanctioned-vessel matters: cargo-recovery claims against vessels later sanctioned, charterparty disputes where a vessel was sanctioned mid-voyage, P&I and war-risk insurance disputes triggered by sanctions designation, and sanctions-screening litigation between buyers and sellers in commodity supply chains. We do not advise on circumvention or evasion of sanctions — both as a matter of UAE law (Federal Decree-Law 26 of 2021) and professional ethics.

Section III · Commodities & reconstruction

8. Force majeure and hardship under UAE law

The UAE Civil Code (Federal Law 5 of 1985) recognises both force majeure (Articles 273 and 893) and hardship (imprévision, Article 249). The doctrines are distinct:

We advise on (i) declaring force majeure or hardship; (ii) responding to a counterparty's declaration; (iii) drafting force-majeure-resilient supply contracts; and (iv) arbitrating disputes under DIAC, ICC, LCIA and ad-hoc UNCITRAL.

9. Oil & gas disruption disputes

Russia-Ukraine, Iran sanctions, Red Sea disruption, OPEC+ output decisions and renewable-energy transition have all generated significant disputes in the oil and gas value chain — from upstream JV restructurings to LNG offtake disputes, refinery feedstock claims, gas-to-power PPA disputes, and storage and trading-position disputes. We act on UAE-onshore matters and on cross-border matters where the UAE is the seat of arbitration. Our energy practice (see Oil & Energy) covers the corporate and project side; this page covers the dispute side.

10. Reconstruction trade — Yemen, Syria, Iraq, Lebanon

UAE-domiciled trading houses, contractors and financial institutions are increasingly active in reconstruction trade and project work across post-conflict and conflict-adjacent jurisdictions. We act on:

This is a fast-evolving practice with significant first-mover advantage for UAE businesses positioned correctly.

11. War-risk insurance and reinsurance disputes

War-risk insurance and reinsurance disputes — particularly arising from Red Sea attacks, Russia-Ukraine cargo losses, and Israel-Iran exchanges — are a meaningful and growing dispute segment. Common dispute types: coverage disputes (named-perils vs war-risk vs "act of war" exclusion); subrogation claims by insurers against carriers and charterers; reinsurance recoveries up the layered tower; and aggregation disputes (whether multiple losses arise from a single "event"). We act for insureds, insurers and reinsurers — with seats commonly in London, DIFC and Bermuda.

Frequently asked questions

Why is the UAE the centre for sanctions and war-risk dispute work?

Geography (between sanctioned jurisdictions and global markets), neutrality (not US/EU jurisdiction — can host disputes between Western and Russian/Iranian/Chinese parties), infrastructure (DIFC/ADGM common-law forums, Jebel Ali third-largest container port, Khalifa Port).

What sanctions regimes do you advise on?

Practical UAE-side compliance and contracting on US OFAC, UK OFSI, EU restrictive measures, UN sanctions, and UAE Federal Decree-Law 26 of 2021. Not a US/UK sanctions firm — we coordinate with US/UK counsel and translate to UAE implications.

Red Sea / Houthi shipping dispute — what can be done?

Force majeure declarations, deviation costs, war-risk premium claims, demurrage/detention, cargo damage, war-risk insurance coverage disputes, charterparty termination. LMAA, SCMA or DIAC seats. UAE-side and lead-counsel work.

Force majeure on commodity supply disrupted by war?

UAE Civil Code Articles 273 and 893 (force majeure), Article 249 (hardship). High bar for force majeure (unforeseeable, unavoidable, external). Hardship more flexible. Advise on declaration, response, drafting, and arbitration.

Sanctioned-vessel and dark-fleet matters?

Yes — on the lawful side: cargo-recovery, mid-voyage sanctions disputes, P&I/war-risk insurance coverage. Strict ethical and regulatory boundary — no circumvention or evasion advice.

Reconstruction work in Yemen, Syria, Iraq, Lebanon?

Trade-finance, contracting/JV structures, sanctions screening, payment-routing, dispute-resolution architecture. Fast-evolving with first-mover advantage.

War-risk insurance and reinsurance disputes?

Yes — coverage disputes, subrogation, reinsurance recoveries, aggregation disputes. Acting for insureds, insurers, reinsurers. London / DIFC / Bermuda seats.


Last updated: 1 May 2026. General information only — not legal advice. Contact us for matter-specific advice.

Sanctions, maritime or war-risk matter?

Confidential, partner-led, with same-business-day turnaround. We are the UAE-side counsel that translates lead-counsel advice into operational UAE outcomes.

Brief us in confidence →