Civil Law and UAE Fraud Litigation and Asset Tracing Procedures

1. Introduction

Fraud litigation in the UAE can involve two closely connected objectives:

establishing civil liability for the fraudulent conduct, and

identifying, preserving and ultimately recovering assets connected with the fraud.

The procedural strategy depends significantly on whether the matter is before the UAE onshore courts, the DIFC Courts, or the ADGM Courts. The distinction is important because the common-law style remedies available in the DIFC and ADGM—such as freezing injunctions, proprietary injunctions and Norwich Pharmacal/Bankers Trust-type disclosure—are materially different from the ordinary onshore UAE attachment regime. (Chambers Practice Guides)

The current UAE framework also requires attention to the Federal Decree-Law No. 25 of 2025 promulgating the new Civil Transactions Law, which came into force on 1 June 2026, as well as the Federal Civil Procedure Code and Federal Evidence Law. (UAE Legislation)

2. Meaning of Fraud in Civil Litigation

Civil fraud generally involves dishonest conduct causing legally recognisable loss or interfering with another person's property or rights.

Typical examples include:

fraudulent misrepresentation;

forged documents;

fraudulent inducement to enter a contract;

diversion of company funds;

misuse of entrusted money;

concealment of assets;

fraudulent transfers;

sham transactions;

misuse of corporate structures;

nominee arrangements;

fraudulent investment schemes;

manipulation of bank transactions;

concealment of beneficial ownership.

A fraud claim can therefore have both a personal dimension and an asset dimension.

Personal claim

The claimant seeks compensation from the wrongdoer.

Proprietary/asset-recovery dimension

The claimant attempts to identify particular money or property and establish that it can be recovered or preserved.

This distinction becomes especially important when the fraudster has transferred money through several companies or bank accounts.

3. UAE Legal Framework

A fraud and asset-tracing dispute can potentially involve:

A. Civil Transactions Law

The substantive civil-law rules governing obligations, liability, compensation, transactions and property.

B. Civil Procedure Code

The procedural framework governing:

claims;

precautionary attachment;

execution;

enforcement;

court applications.

C. Evidence Law

Federal Decree-Law No. 35 of 2022 governs evidence in civil and commercial transactions. It contains provisions concerning documentary evidence, electronic evidence, expert evidence, witness evidence and forgery. (UAE Legislation)

D. Criminal legislation

Where conduct also constitutes a crime, criminal proceedings may operate alongside civil proceedings.

E. Anti-money-laundering legislation

Where fraud involves laundering or concealment of proceeds, AML legislation and regulatory mechanisms may become relevant.

4. Civil Fraud Litigation Versus Criminal Fraud

A fraudulent transaction can produce parallel proceedings.

The two processes can interact, but they serve different purposes.

A claimant should therefore avoid assuming that filing a criminal complaint automatically provides complete civil recovery of all misappropriated assets.

5. Initial Fraud-Litigation Strategy

A claimant should normally establish five preliminary matters:

1. What happened?

Identify the fraudulent transaction.

2. Who participated?

Identify:

principal wrongdoer;

directors;

shareholders;

intermediaries;

recipients;

banks;

companies;

nominees.

3. What was lost?

Calculate:

principal;

interest;

consequential losses;

expenses.

4. Where did the money go?

Construct the transaction chain.

5. What is the risk of dissipation?

This is critical because a successful judgment is of limited practical value if assets have already disappeared.

6. Asset Tracing

Asset tracing is the process of reconstructing the movement of property or money.

A simplified tracing chain may look like:

Victim → Bank Account A → Company B → Individual C → Company D → Property/Investment

The objective is to establish:

the original asset;

each transfer;

the recipient;

the nature of each transaction;

whether the asset remains identifiable;

whether the proceeds can be traced;

whether third parties received the property;

whether assets were transferred to defeat creditors.

7. Types of Assets That May Be Traced

Modern UAE fraud litigation may involve:

bank accounts;

real estate;

shares;

securities;

company interests;

vehicles;

vessels;

aircraft;

cryptocurrency;

stablecoins;

receivables;

investment accounts;

insurance proceeds;

commodities;

intellectual-property rights;

digital assets.

Complex fraud may require tracing through multiple jurisdictions.

8. Bank-Account Tracing

Bank records can be particularly important.

Evidence may establish:

date of transfer;

amount;

sender;

recipient;

reference;

subsequent transfers;

withdrawals;

conversion into other assets.

However, obtaining information from banks is subject to applicable procedural and confidentiality rules.

This is one reason why the DIFC/ADGM disclosure mechanisms can be especially significant in appropriate cases.

9. Precautionary Attachment in Onshore UAE Courts

The onshore UAE system uses precautionary attachment rather than the broad common-law freezing injunction model.

Current UAE practice guidance explains that Article 111 of Cabinet Decision No. 57 of 2018 permits an applicant to seek precautionary attachment where there is a serious concern that assets may disappear, be concealed or otherwise become unavailable for satisfying a claim. (Chambers Practice Guides)

Circumstances can include situations where:

the debtor has no permanent residence in the UAE;

the creditor fears that the debtor will abscond;

assets may be removed;

assets may be concealed;

securities are at risk of dissipation.

The application can potentially be made without prior notice, but the claimant must subsequently commence the substantive claim within the applicable procedural period. Current guidance identifies an eight-day period for filing the substantive claim following such an order. (Chambers Practice Guides)

10. Third-Party Asset Attachment

An important feature of UAE attachment procedure is that attachment may extend to property held by third parties.

For example:

Fraudster → Bank Account → Bank

The claimant may seek attachment against the relevant bank-held funds rather than merely against assets physically possessed by the defendant.

Current procedural guidance recognises that precautionary attachment can operate over assets in the possession of third parties, including bank accounts. (Chambers Practice Guides)

11. Limits of Onshore UAE Attachment

A precautionary attachment is principally a preservation mechanism.

It does not automatically establish that:

the claimant owns the attached asset;

the asset was stolen;

the defendant is liable;

the claimant has a proprietary interest in the asset.

This distinction is important.

Current UAE fraud guidance notes that onshore UAE civil courts generally do not recognise the same broad proprietary fraud remedies available in common-law jurisdictions; an attachment preserves specified assets but does not itself create a proprietary interest in them. (Chambers Practice Guides)

12. Evidence in Fraud Proceedings

Federal Decree-Law No. 35 of 2022 provides the UAE civil and commercial evidence framework. (UAE Legislation)

Relevant evidence can include:

contracts;

invoices;

bank statements;

emails;

WhatsApp communications;

accounting records;

electronic transactions;

company records;

shareholder records;

expert reports;

audit reports;

witness evidence;

forensic accounting evidence.

Electronic evidence can be particularly important where fraudulent transactions were arranged through digital communications.

13. Forged Documents

Fraud litigation frequently involves allegations that:

signatures were forged;

contracts were fabricated;

invoices were altered;

electronic records were manipulated;

corporate documents were falsified.

The UAE Evidence Law contains specific provisions concerning forgery.

For example, where a party raises a forgery claim, the law provides a procedural framework for investigating the alleged forgery; the court may also reject or invalidate an instrument where its condition and circumstances demonstrate invalidity. (UAE Legislation)

14. Court-Appointed Experts

Expert evidence can be extremely important in complicated fraud litigation.

An expert may reconstruct:

financial transactions;

accounting entries;

company ownership;

payment flows;

valuation;

losses;

relationships between entities.

For example:

Account 1 → AED 20 million → Company A → AED 15 million → Company B → property purchase

A forensic accounting analysis can help establish that sequence.

15. DIFC Courts: A Different Procedural Environment

The DIFC Courts operate under a common-law influenced procedural framework.

This is particularly relevant to sophisticated fraud and asset-tracing disputes.

The DIFC Courts can grant remedies including:

freezing orders;

proprietary injunctions;

asset-disclosure orders;

information orders;

third-party disclosure;

worldwide freezing orders in appropriate circumstances.

The DIFC Court of Appeal's decision in Carmon Reestrutura-engenharia E Serviços Técnicos Especiais (SU) LDA v Antonio Joao Catete Lopes Cuenda [2024] DIFC CA 003 confirmed important jurisdictional principles concerning worldwide freezing orders in support of foreign proceedings. (DIFC Courts)

16. Case Law 1 — SBM Bank (Mauritius) Ltd v Renish Petrochem FZE [2018] DIFC CFI 054

This is an important UAE fraud authority.

SBM alleged that it had been induced into a financing arrangement through fraudulent representations concerning an oil transaction.

The DIFC Court granted a freezing order.

The evidence included:

suspicious payment patterns;

abandonment of business premises;

disappearance of the relevant individuals;

failure to comply with disclosure obligations;

transactions displaying characteristics of a sophisticated fraud.

The court ultimately found that Renish and Mr Mehta had conspired to defraud SBM and entered judgment against them. (DIFC Courts)

Principle

Fraud litigation can combine:

substantive fraud claim + freezing order + asset disclosure + banking evidence.

This case demonstrates the practical importance of preserving financial evidence before assets disappear.

17. Case Law 2 — Larmag Holding B.V. v First Abu Dhabi Bank PJSC & Ors, DIFC CFI 054/2019

The dispute concerned alleged deceitful misappropriation of securities.

The DIFC Court had previously granted a worldwide freezing order covering assets within and outside Dubai.

The order required disclosure of worldwide assets exceeding the specified threshold and included obligations concerning subsequent changes in the defendants' asset position. (DIFC Courts)

Principle

A freezing order can be accompanied by positive disclosure obligations.

It is therefore not merely:

"Do not dispose of your assets."

It can also require:

"Tell the claimant and the Court what assets you have."

Importance for tracing

Disclosure allows the claimant to compare:

known transactions;

declared assets;

company interests;

bank records;

property ownership.

Inconsistencies can become significant evidence.

18. Case Law 3 — Skatteforvaltningen v FFA Private Bank (Dubai) Ltd, [2024] DIFC CFI 004

This is particularly important for third-party asset tracing.

The Danish tax authority alleged that millions of pounds and euros received into accounts at FFA Private Bank represented proceeds of a large-scale fraud.

The DIFC Court granted a Norwich Pharmacal/Bankers Trust-type order requiring information concerning:

account holders;

dealings with the money;

receipts of the claimant's funds;

information needed to identify recipients and trace assets. (DIFC Courts)

Principle

A claimant may be able to obtain information from a third party that possesses information necessary to identify wrongdoers or trace fraud proceeds.

Importance

This is particularly valuable where:

the claimant knows money entered a UAE bank but does not know the identity of the recipient.

19. Case Law 4 — Carmon Reestrutura-engenharia v Cuenda, [2024] DIFC CA 003

The claimant alleged that more than USD 20 million had been misappropriated.

Evidence indicated that some of the funds had been transferred into accounts maintained at Emirates NBD.

A Hong Kong court had also issued a worldwide injunction concerning the funds.

The DIFC Court of Appeal considered whether the DIFC Courts possessed jurisdiction and power to issue a worldwide freezing order in circumstances involving foreign proceedings. (DIFC Courts)

Principle

The DIFC Courts can, in appropriate circumstances, exercise interim jurisdiction in support of foreign proceedings where the conditions for the relevant jurisdiction and remedy are satisfied.

Asset-tracing significance

Cross-border fraud frequently involves:

foreign proceedings + UAE bank accounts + UAE assets.

Carmon demonstrates the importance of the DIFC's supporting jurisdiction.

20. Case Law 5 — Trafigura PTE Ltd & Trafigura India Pvt Ltd v Prateek Gupta & Ginni Gupta, [2025] DIFC CA 001

This litigation concerned allegations of a very substantial commodities fraud.

The underlying allegations involved payments exceeding USD 534 million for cargo represented as LME-grade nickel which allegedly turned out to contain less valuable commodities.

Worldwide freezing orders and proprietary injunctions were obtained in the foreign proceedings.

The DIFC proceedings concerned, among other things, asset protection and disclosure relating to assets allegedly held for the benefit of the principal defendant. (DIFC Courts)

The DIFC Court of Appeal discussed the court's power to grant interim remedies, including freezing orders, in support of foreign proceedings and enforcement. (DIFC Courts)

Principle

Asset-tracing proceedings can involve:

foreign fraud proceedings;

UAE assets;

third-party assets;

beneficial ownership;

freezing orders;

disclosure.

This makes jurisdictional planning crucial.

21. Case Law 6 — Techteryx Ltd v Aria Commodities DMCC & Ors, [2025] DIFC DEC 001

This is a particularly important modern asset-tracing case involving cryptocurrency/stablecoin-related allegations.

The underlying Hong Kong proceedings concerned an alleged fraud involving reserves backing a stablecoin.

The DIFC Court continued:

proprietary injunctions; and

freezing injunctions.

The Court considered orders directed toward the alleged misappropriated money and its traceable proceeds, together with asset disclosure. (DIFC Courts)

Principle

Asset tracing in UAE litigation is no longer confined to conventional property.

It can involve:

cryptocurrency;

stablecoins;

fiat reserves;

bank accounts;

corporate structures;

digital assets.

The case illustrates how modern fraud litigation can require both proprietary relief and general asset preservation.

22. Case Law 7 — GTC Trading S.A. v Hazem Abdolshahid Mahmoudi Rashed & Ors, DIFC CFI 046/2023 / ENF 022/2023 / ENF 023/2023

The DIFC proceedings involved enforcement-related challenges to orders including:

a worldwide freezing order;

a charging order;

enforcement measures.

The Court's September 2024 order records the procedural history surrounding those orders and the applications challenging them. (DIFC Courts)

Principle

Freezing and enforcement orders are subject to procedural safeguards and can be challenged by affected defendants.

Importance

Asset preservation is not equivalent to automatic recovery.

The claimant must still move through the relevant stages:

interim protection → substantive judgment → enforcement → realisation of assets.

23. Case Law 8 — Massun v Mousi & Ors, [2022] DIFC CA 003/004

This case involved allegations that assets—including a yacht and Spanish property—had been misappropriated through complex corporate structures.

The case illustrates an important question in asset tracing:

Who legally owns the asset?

The claimant alleged beneficial ownership through corporate structures, while the appeal considered whether the assets could properly be characterised as belonging to the claimant for purposes of the claim. (DIFC Courts)

Principle

Beneficial ownership and legal ownership must be carefully distinguished.

A claimant cannot necessarily establish a proprietary claim merely by demonstrating that it ultimately owns shares in a company that owns the relevant property.

Corporate structure analysis can therefore be fundamental to asset tracing.

24. Case Law 9 — Nadil & Noshaba v Nameer & Naseema

The DIFC Court of Appeal considered an application for a UAE-wide freezing order following the introduction of the 2025 DIFC Court Law.

The Court granted interim relief on the basis that there was at least a reasonably arguable case concerning jurisdiction and the merits, while expressly noting that the ex parte decision did not finally determine the jurisdictional issue. (DIFC Courts)

Principle

In urgent asset-preservation proceedings, courts may consider interim relief before final determination of all jurisdictional questions.

Importance

Fraud claims often involve urgency because:

delay may permit the defendant to move or conceal assets.

25. Worldwide Freezing Orders

A worldwide freezing order is designed to restrain a defendant from dealing with assets within the relevant scope of the order.

The DIFC rules expressly contemplate freezing orders restraining dealings with assets whether located inside or outside the jurisdiction in appropriate circumstances. (DIFC Courts)

Such an order can be particularly important where a defendant has:

UAE bank accounts;

offshore companies;

foreign property;

securities;

cryptoassets;

assets held through nominees.

However, the practical effectiveness of a worldwide order depends on jurisdiction, service, recognition and enforcement in the countries where assets are located.

26. Proprietary Injunction Versus Freezing Order

These remedies should not be confused.

Proprietary injunction

The claimant says, in substance:

"That particular asset or its traceable proceeds belong to me."

The remedy therefore protects the claimant's alleged proprietary interest.

Freezing order

The claimant says:

"Even if these assets ultimately belong to the defendant, they should not be dissipated because they may be needed to satisfy my judgment."

The two remedies can coexist.

The Techteryx proceedings illustrate this distinction: the application included a proprietary injunction concerning misappropriated monies and traceable proceeds alongside a freezing order covering assets up to a specified value. (DIFC Courts)

27. Disclosure Orders

Asset disclosure is often the key to successful tracing.

A disclosure order can require information about:

bank accounts;

companies;

property;

securities;

beneficial ownership;

transfers;

assets held for another person;

transactions involving related parties.

In Larmag, the worldwide freezing order included a requirement to disclose assets above a specified threshold. (DIFC Courts)

28. Why Disclosure Is Critical in Fraud Cases

Fraudsters frequently leave incomplete documentary trails.

The DIFC Court in VTB Bank PJSC v Kuanyshev & Ors recently discussed the particular importance of asset disclosure accompanying freezing injunctions in fraud cases, noting that such information can allow the claimant to reconstruct transactions and trace assets before dissipation. (DIFC Courts)

This produces a practical sequence:

Freeze → disclose → investigate → trace → identify asset → establish ownership → enforce/recover.

29. Norwich Pharmacal-Type Relief

A Norwich Pharmacal order is an information-disclosure remedy traditionally associated with common-law jurisdictions.

It can be particularly useful where:

a third party has relevant information;

the claimant cannot identify the wrongdoer or recipient;

the information is needed to pursue a legal claim.

In Skatteforvaltningen v FFA Private Bank, the DIFC Court granted Norwich Pharmacal/Bankers Trust relief concerning funds allegedly linked to fraud. (DIFC Courts)

This can be extremely useful where a bank or intermediary possesses information that the claimant cannot otherwise obtain.

30. Bankers Trust-Type Relief

Bankers Trust relief is directed toward obtaining banking information necessary to trace misappropriated property.

For example:

Victim → unknown account → UAE bank → second account → unknown company

The claimant may need information from the bank to identify the next link in the chain.

The Skatteforvaltningen case demonstrates the importance of this mechanism in identifying recipients and tracing alleged fraud proceeds. (DIFC Courts)

31. Fraudulent Transfers and Non-Enforceability

Asset tracing also intersects with transactions designed to defeat creditors.

The new Civil Transactions Law contains provisions concerning the non-enforceability of dispositions against affected creditors.

For example, the new law provides that once a disposition has been adjudged non-enforceable, creditors harmed by that disposition can benefit from the judgment. It also establishes limitation periods for such claims. (UAE Legislation)

This can become relevant where a debtor transfers:

property to relatives;

shares to controlled companies;

assets to nominees;

money to connected businesses.

The claimant may seek to challenge the transaction rather than merely pursue the original debtor.

32. Corporate Structures and Asset Tracing

Fraudsters may use several corporate entities.

Example:

Individual A
↓
Holding Company B
↓
Company C
↓
Company D
↓
Property E

The central question becomes:

Does the claimant have a legally recognisable claim against E, or merely a personal claim against A?

Massun demonstrates why corporate ownership and beneficial ownership must be analysed carefully. (DIFC Courts)

33. Nominee Arrangements

A defendant may hold assets:

through a relative;

through an employee;

through a company;

through a nominee shareholder;

through an offshore structure.

The claimant must distinguish between:

legal title and beneficial control.

Evidence may include:

payment records;

shareholder agreements;

corporate correspondence;

instructions to nominees;

source-of-funds records;

accounting entries;

communications.

34. Asset Tracing Through Related Parties

Suppose:

Fraudster → AED 10 million → Brother → Property

The fact that the property is registered in the brother's name does not necessarily end the inquiry.

The court may need to consider:

who supplied the purchase money;

the purpose of the transfer;

whether the recipient knew of the fraud;

whether consideration was paid;

whether the transfer was genuine;

whether the recipient was acting as nominee.

The precise remedy depends on the applicable legal regime.

35. Cryptocurrency and Digital Assets

Modern UAE fraud litigation increasingly involves:

Bitcoin;

stablecoins;

tokenised assets;

crypto exchanges;

digital wallets.

Techteryx demonstrates how the DIFC Courts have dealt with alleged fraud involving stablecoin reserves and the relationship between cryptocurrency and identifiable underlying assets. (DIFC Courts)

Tracing may require:

wallet addresses;

transaction hashes;

exchange records;

blockchain analysis;

KYC records;

bank-to-exchange transactions;

conversion records.

36. Search Orders and Onshore/DIFC Distinction

The distinction between jurisdictions is important.

Current UAE fraud guidance states that ordinary onshore UAE civil courts do not generally provide the same search-order and freezing-injunction remedies familiar from English common law, although precautionary attachment is available. DIFC and ADGM courts, by contrast, can provide common-law style interim remedies in appropriate cases. (Chambers Practice Guides)

Therefore, the question:

"Can I obtain a freezing order in the UAE?"

has no single answer.

The answer depends upon which UAE judicial system has jurisdiction.

37. Standard Asset-Tracing Workflow

A practical fraud claim can be organised as follows:

Stage 1 — Evidence preservation

Collect:

contracts;

emails;

WhatsApp messages;

bank statements;

invoices;

company documents;

accounting records;

blockchain records.

Stage 2 — Transaction reconstruction

Create a chronological payment schedule.

Stage 3 — Identify recipients

Determine:

individuals;

companies;

banks;

intermediaries.

Stage 4 — Identify assets

Search for:

real estate;

shares;

bank balances;

vehicles;

companies;

investments;

digital assets.

Stage 5 — Emergency preservation

Seek:

precautionary attachment;

freezing order;

proprietary injunction;

disclosure order,

depending on the jurisdiction.

Stage 6 — Commence substantive proceedings

Establish:

fraud;

breach;

loss;

causation;

ownership/proprietary entitlement where applicable.

Stage 7 — Obtain information

Use appropriate disclosure mechanisms.

Stage 8 — Trace proceeds

Connect the original property with substitute assets.

Stage 9 — Obtain judgment

Establish liability and the amount recoverable.

Stage 10 — Enforcement

Execute against assets legally available for satisfaction of the judgment.

38. Important Procedural Difference

This difference is central to UAE fraud litigation strategy. (Chambers Practice Guides)

39. Evidentiary Challenges

Fraud cases often present problems involving:

A. Circumstantial evidence

Direct evidence of fraudulent intention may be unavailable.

B. Digital communications

Messages may need authentication and contextual interpretation.

C. Corporate opacity

The beneficial owner may differ from the registered shareholder.

D. Multiple jurisdictions

Funds may cross several countries within hours.

E. Third-party confidentiality

Banks and intermediaries may hold critical information.

F. Dissipation

By the time proceedings begin, assets may have moved.

These difficulties explain the importance of urgent interim relief.

40. Defences to Asset-Tracing Applications

A defendant may argue:

the claimant has no good arguable case;

the asset belongs to the defendant independently;

the transfer was legitimate;

there was valuable consideration;

the claimant cannot establish proprietary ownership;

the asset was acquired before the alleged fraud;

the court lacks jurisdiction;

the order is too broad;

disclosure obligations are disproportionate;

the claimant failed to make full and frank disclosure;

the claimant has an adequate alternative remedy.

The court must balance effective asset preservation with procedural fairness.

41. Wrongful Freezing or Attachment

A claimant seeking emergency relief must proceed carefully.

Under the onshore attachment framework, the applicant may be required to provide an undertaking concerning losses suffered by the defendant if the attachment was improperly obtained. Current UAE procedural guidance specifically identifies an undertaking to indemnify the defendant where the attachment was obtained on fraudulent grounds. (Chambers Practice Guides)

Therefore:

urgent relief carries corresponding responsibility.

42. Enforcement After Judgment

Winning the fraud claim is not necessarily the end.

The claimant must determine:

what assets remain;

where they are located;

who owns them;

whether they are encumbered;

whether another creditor has priority;

whether enforcement is possible;

whether foreign recognition is required.

The UAE Civil Procedure Code contains detailed attachment and execution provisions, including exemptions from attachment. For example, Article 242 identifies categories of property that generally cannot be attached, subject to statutory exceptions. (UAE Legislation)

43. Foreign Judgments and Cross-Border Fraud

Fraud often involves:

foreign claimant + UAE defendant + UAE bank + offshore company.

The claimant may therefore need:

foreign judgment;

recognition/enforcement;

UAE interim protection;

UAE asset disclosure;

local execution.

The DIFC jurisprudence in Carmon and Trafigura illustrates the potential importance of interim DIFC relief in support of foreign proceedings and enforcement. (DIFC Courts)

44. Six Core Case-Law Principles

These cases should be distinguished according to their jurisdictions and factual contexts rather than treated as a single uniform UAE fraud doctrine.

45. Conclusion

UAE fraud litigation and asset tracing requires a combination of substantive civil liability, evidence, urgent asset preservation, disclosure and enforcement.

The basic strategy can be expressed as:

Identify the fraud → preserve evidence → identify the asset trail → prevent dissipation → obtain disclosure → establish liability/ownership → obtain judgment → enforce.

For onshore UAE proceedings, precautionary attachment is the principal mechanism for protecting specified assets pending litigation. Article 111 of the implementing procedural framework is particularly important in this respect. (Chambers Practice Guides)

For DIFC proceedings, the available toolkit can be broader, including freezing orders, proprietary injunctions and Norwich Pharmacal/Bankers Trust-type disclosure. SBM Bank, Larmag, Skatteforvaltningen, Carmon, Trafigura and Techteryx demonstrate how these remedies operate in sophisticated fraud and asset-tracing disputes. (DIFC Courts)

The most important practical distinction is therefore not simply whether fraud occurred, but which UAE court has jurisdiction, what type of remedy is sought, where the assets are located, and whether the claimant is asserting a personal claim, a proprietary claim, or both.