Civil Law and UAE Market Misconduct Claims

1. Introduction

Market misconduct refers to conduct that undermines the integrity, fairness, transparency or proper functioning of financial markets. In the UAE, it can arise in securities markets, exchanges, investment activities and, increasingly, crypto-token and digital-asset markets.

Typical forms include:

• insider dealing;
• market manipulation;
• wash trades;
• false or misleading market information;
• dissemination of misleading information;
• front-running;
• fraudulent trading;
• artificial pricing;
• misuse of confidential information;
• abusive trading strategies;
• failure of regulated intermediaries to identify or report suspected market abuse.

The UAE framework is not contained in one single civil-law provision. It is distributed across securities-market legislation, regulatory rules, company law, DIFC/DFSA legislation, ADGM legislation, and general principles of civil liability.

An important distinction must be made between mainland UAE securities regulation and DIFC/ADGM financial-market regimes. The latter have their own financial-services legislation and courts.

2. Meaning of a Market Misconduct Claim

A market misconduct claim may arise where conduct:

1. creates a false or misleading appearance concerning a security;
2. artificially affects supply, demand or price;
3. uses inside information improperly;
4. involves fraudulent or deceptive conduct;
5. causes loss to investors;
6. breaches regulatory obligations imposed on market participants.

Market misconduct therefore has both a public/regulatory dimension and, in appropriate circumstances, a private civil-law dimension.

Regulatory dimension

The regulator may:

• investigate;
• impose administrative penalties;
• suspend or restrict activities;
• refer matters for prosecution;
• require disclosure or corrective measures.

Civil dimension

An affected party may potentially seek:

• compensation;
• injunctions;
• restitution;
• preservation of assets;
• disclosure of information;
• damages for fraud or unlawful conduct.

The availability of a private damages claim depends upon the applicable legislation and the claimant's legal cause of action.

3. UAE Mainland Framework

For mainland UAE markets, the principal institutional framework involves the Securities and Commodities Authority (SCA) and the securities-market legislation and regulations applicable to licensed entities and listed companies.

The SCA's regulatory system expressly provides mechanisms for reporting capital-market violations involving stock-market activities and financial services under its supervision.

The SCA has historically identified and referred cases involving:

• insider trading;
• market manipulation;
• front-running.

For example, its 2018 enforcement statistics recorded 19 insider-trading cases, 10 other market-manipulation cases and 2 front-running cases detected through electronic monitoring.

These regulatory statistics should not be confused with judicial findings in individual cases.

4. DIFC Market Misconduct Framework

The DIFC has a particularly developed statutory regime.

Article 54 of the DIFC Markets Law prohibits conduct relating to investments that a person knows or reasonably ought to know:

• creates or contributes to a false or misleading impression concerning supply, demand or price;
• creates or is likely to create an artificial price; or
• perpetrates fraud.

The provision applies to conduct occurring in the DIFC or elsewhere in the circumstances covered by the statute.

This makes the DIFC framework particularly relevant to civil claims arising from market manipulation.

5. Main Types of Market Misconduct

A. Insider Trading

Insider trading generally involves trading while possessing material non-public information or otherwise improperly using inside information.

Examples could include knowledge of:

• unpublished financial results;
• takeover negotiations;
• major acquisitions;
• insolvency;
• major contracts;
• regulatory decisions;
• significant litigation;
• undisclosed corporate restructuring.

The legal concern is that the insider obtains an informational advantage that ordinary investors do not possess.

6. Market Manipulation

Market manipulation involves conduct intended or reasonably capable of creating an artificial or misleading market appearance.

Examples include:

• wash trades;
• matched orders;
• marking the close;
• artificial price support;
• artificial price suppression;
• circular trading;
• coordinated transactions;
• dissemination of false information.

The important question is not simply whether the price changed.

The legal inquiry may concern whether the conduct distorted the normal operation or appearance of the market.

7. Wash Trades

A wash trade involves transactions where buying and selling activity is structured so that there is little or no genuine change in beneficial ownership or genuine economic exposure.

The transactions can create an appearance of:

• increased trading volume;
• market interest;
• liquidity;
• price momentum.

The DIFC courts recently considered this issue directly in Al Ramz Capital LLC v DFSA.

8. Case Law 1 — Emirates REIT (CEIC) Plc & Equitativa Dubai Ltd v Nasdaq Dubai Ltd

CFI 054/2020 — DIFC Court of First Instance

This is one of the most directly relevant UAE cases concerning market manipulation.

Emirates REIT's shares were traded on Nasdaq Dubai and were relatively illiquid.

On several dates in February 2020, small sell orders were placed near the beginning of the closing auction at prices substantially below the previous transaction and prevailing best bid. The applicants argued that the trades artificially reduced the closing price—known as “marking the close.”

The applicants sought information from Nasdaq Dubai concerning the traders.

Court's approach

The Court concluded that the trades had the hallmarks of market manipulation and accepted that there was a good arguable case that Article 54 had been breached by creating an artificial closing price.

However, the Court did not automatically conclude that the applicants had established a compensable loss.

The evidence did not sufficiently establish that the alleged manipulation actually caused the claimed financial losses.

Principle

Evidence of potentially manipulative conduct and proof of compensable loss are separate questions.

Importance

This is an extremely important principle for civil market-misconduct litigation.

A claimant must distinguish:

Wrongdoing

from

causation

and

actual recoverable loss.

9. Article 54 and Private Compensation

The Emirates REIT judgment is particularly important because it explained that breach of Article 54 can support injunctive relief and, under the applicable DIFC regulatory framework, intentional, reckless or negligent breach can give rise to compensation for loss or damage caused by the conduct.

Therefore, the DIFC framework does not treat market abuse exclusively as a regulatory offence.

It can potentially have private-law consequences.

10. Case Law 2 — Al Ramz Capital LLC v Dubai Financial Services Authority

CFI 087/2024 — DIFC Court of First Instance

This is another particularly important market-misconduct case.

The DFSA alleged that a client's transactions executed through Al Ramz were wash trades that produced a spike in the relevant securities' price.

The DFSA alleged that this created a false appearance of trading activity contrary to Article 54(a) of the Markets Law.

The DFSA also alleged that Al Ramz had reasonable grounds to suspect market abuse and therefore had a reporting obligation under the applicable DFSA rules.

A USD 25,000 fine was imposed for the alleged failure to report the suspected market abuse.

The subsequent DIFC Court proceedings concerned, among other matters, the regulatory process and publication of the decision.

Principle

A regulated intermediary's responsibilities may extend beyond simply executing client orders.

It may have obligations concerning:

• compliance systems;
• transaction monitoring;
• identifying suspicious transactions;
• reporting suspected market abuse;
• cooperation with regulators.

Importance

The case demonstrates the difference between:

Direct market misconduct by a trader

and

regulatory/compliance responsibility of an intermediary.

11. Case Law 3 — Larmag Holdings BV v First Abu Dhabi Bank PJSC & FAB Securities LLC

CFI 030/2019 — DIFC Court of First Instance

Larmag alleged that it had been induced by fraud to sell and transfer corporate bonds to an account associated with the alleged wrongdoers.

The DIFC Court granted an interim injunction restraining the respondents from dealing with or diminishing the value of specified bonds while the dispute proceeded.

The case is significant because the respondents included:

• First Abu Dhabi Bank;
• FAB Securities;
• entities operating in the securities market.

The proceedings also concerned the jurisdictional position of a UAE-regulated institution operating as a recognised member of Nasdaq Dubai.

Principle

Where there is an arguable case of fraud involving financial instruments, courts can use interim protective remedies to preserve assets pending determination of the substantive claim.

Market-misconduct relevance

The case illustrates the connection between:

• fraudulent securities transactions;
• financial intermediaries;
• asset preservation;
• injunctions;
• jurisdiction.

12. Case Law 4 — KBC Aldini Capital Ltd v David Baazov & Others

CFI 002/2017 — DIFC Court

This litigation concerned allegations relating to financial transactions and involved a defendant who was also subject to separate insider-trading proceedings in Canada.

The DIFC Court's orders included consideration of service of proceedings on the defendant in connection with the foreign insider-trading litigation.

Principle

Market misconduct can generate parallel proceedings in different jurisdictions, particularly where securities transactions, financial institutions and investors operate internationally.

Importance for UAE law

A UAE/DIFC market-misconduct dispute can involve:

• UAE regulatory proceedings;
• foreign securities regulators;
• foreign criminal or civil proceedings;
• cross-border asset preservation;
• service outside the jurisdiction.

The case therefore illustrates the international dimension of market misconduct rather than establishing a standalone UAE insider-trading liability rule.

13. Case Law 5 — David Lawrence Haigh v GFH Capital Ltd & Hisham Al Rayes

CFI 034/2014 — DIFC Court

This case concerned a dispute involving shares that were allegedly not transferred as agreed and allegations that the value of shares had been affected by alleged manipulation.

The pleadings initially referred to share-price manipulation, although that allegation did not ultimately form part of the pleaded claim in the manner originally suggested.

Principle

The case illustrates an important procedural point:

An allegation of market manipulation must be properly pleaded and connected to a recognised legal cause of action and loss.

Simply alleging that a share price was manipulated is not necessarily sufficient.

The claimant must establish:

• the relevant wrongful conduct;
• legal basis;
• causation;
• resulting loss.

14. Case Law 6 — Gate Mena DMCC / Huobi Mena FZE v Tabarak Investment Capital Ltd

Digital Economy Court, 2026

This case concerns digital assets rather than conventional listed securities.

The DIFC Digital Economy Court considered disputes involving Bitcoin and contractual obligations surrounding the custody and transfer of digital assets. The 2026 judgment followed earlier proceedings concerning the same dispute.

Relevance to market misconduct

The case is important for the development of UAE financial-market law because the boundary between:

• securities;
• crypto tokens;
• digital assets;
• investment products;
• financial services

is increasingly important.

Market misconduct rules can potentially apply to regulated digital-asset markets where the relevant legislation brings the instrument within its scope.

The newer DIFC Markets Law wording itself expressly addresses Investments or Crypto Tokens in Article 54.

Principle

The technological form of an investment does not necessarily remove it from regulatory or contractual scrutiny.

15. Case Law Summary

Important qualification: the first two cases are the strongest direct DIFC authorities on market manipulation. The other cases are relevant to the broader civil-law consequences, securities fraud, cross-border misconduct, and digital-market context; they should not be described as six decisions each conclusively establishing the same market-abuse rule.

16. Civil Liability for Market Misconduct

A market-misconduct claim can potentially involve several elements.

1. Wrongful conduct

There must be conduct prohibited by:

• securities legislation;
• regulatory rules;
• contract;
• general civil law; or
• another applicable legal rule.

2. Causation

The claimant must establish a connection between the misconduct and the loss.

3. Damage

The claimant must establish an actual legally recoverable loss.

4. Legal responsibility

The defendant must be legally responsible for the conduct.

This can be particularly complicated where several participants are involved.

17. Why Causation Is Difficult

Suppose a person manipulates a share price from AED 10 to AED 12.

An investor purchases at AED 12.

The price later falls to AED 8.

The investor cannot necessarily say:

“I lost AED 4, therefore the manipulator must pay AED 4.”

The claimant may need to establish:

• that manipulation actually affected the purchase price;
• that the claimant relied on the affected market;
• the extent of artificial inflation;
• when the artificial price ceased;
• whether other market factors caused the decline;
• whether the claimant would have purchased the security anyway.

This explains the importance of the Emirates REIT decision.

18. Market Manipulation and Unlawful Conspiracy

Market manipulation can sometimes be associated with coordinated conduct.

For example:

A + B + C

↓

coordinate trades

↓

artificially affect price

↓

investors react

↓

financial loss

Where the applicable legal requirements are satisfied, this may raise questions of:

• conspiracy;
• joint wrongdoing;
• aiding or facilitating misconduct;
• regulatory liability.

In Emirates REIT, the applicants specifically contemplated an unlawful-conspiracy claim based on alleged coordinated manipulation, although the Court was not making a final determination of such liability at that interlocutory stage.

19. Duties of Brokers and Market Intermediaries

A broker or recognised market member is not necessarily liable for every improper trade executed by a client.

However, regulated intermediaries may have specific obligations concerning:

• monitoring;
• compliance;
• suspicious transactions;
• AML/KYC;
• market-abuse detection;
• reporting;
• cooperation with regulators.

The Al Ramz proceedings demonstrate the importance of these obligations.

The DFSA alleged that the institution had reasonable grounds to suspect market abuse and had failed to report it as required.

Therefore:

Execution of a client's order and regulatory responsibility for detecting suspicious activity are separate legal questions.

20. Insider Trading and Civil Claims

Insider trading can involve several relationships.

Insider → Investor

The insider possesses material information unavailable to the investor.

Director → Company

The director may breach duties owed to the company.

Employee → Employer

The employee may breach confidentiality or fiduciary obligations.

Broker → Regulator

The intermediary may breach regulatory reporting obligations.

Thus, the same factual event can potentially generate:

• regulatory liability;
• criminal liability;
• contractual liability;
• fiduciary liability;
• civil compensation claims.

21. False or Misleading Information

Market misconduct can also involve dissemination of false or misleading information.

Examples:

• false financial statements;
• misleading earnings information;
• fabricated corporate announcements;
• false takeover rumours;
• misleading investor presentations;
• manipulated valuation information.

The legal analysis should distinguish between:

Incorrect statement

A statement that turns out to be wrong.

and

Misleading statement

A statement presented in a manner that creates a materially misleading impression.

and

Intentional deception

A statement made with fraudulent intent.

The legal consequences can differ significantly.

22. Market Misconduct and Company Directors

Directors of listed companies occupy an especially important position.

Potential misconduct may involve:

• misuse of inside information;
• improper disclosure;
• manipulation of company accounts;
• misleading market announcements;
• unauthorised disposal of corporate assets;
• related-party transactions;
• improper trading.

The SCA has recently referred board members of an unlisted public joint-stock company to the Public Prosecution following an inspection that identified alleged violations of Federal Decree-Law No. 32 of 2021 on Commercial Companies.

That regulatory action is not itself a judicial finding of civil liability, but it demonstrates the interaction between company law and financial-market enforcement.

23. Misleading Investors

A particularly serious form of market misconduct occurs where investors are induced to purchase securities based upon false information.

A civil claim may require analysis of:

• representation;
• knowledge;
• reliance;
• causation;
• loss;
• available remedies.

The fact that the investor made the investment voluntarily does not necessarily eliminate liability if the investment decision was induced by legally wrongful deception.

24. Market Manipulation Through Technology

Modern market misconduct can occur through:

• algorithmic trading;
• high-frequency trading;
• automated order placement;
• coordinated online activity;
• social-media campaigns;
• bot trading;
• spoofing-type strategies;
• artificial liquidity;
• crypto-token trading.

Technology can make the conduct more difficult to detect but does not necessarily change the underlying legal question:

Did the conduct unlawfully distort the market or create a false or misleading appearance?

The DIFC framework is particularly notable because Article 54 covers conduct concerning Investments and Crypto Tokens.

25. Evidence in Market-Misconduct Claims

Market misconduct is usually evidence-intensive.

Important evidence may include:

• trading records;
• order-book data;
• timestamps;
• communications;
• emails;
• chat messages;
• telephone records;
• brokerage records;
• beneficial-ownership information;
• account records;
• corporate announcements;
• financial statements;
• blockchain records;
• algorithm logs.

The court may need to reconstruct the entire trading sequence.

26. Expert Evidence

Experts may be required to determine:

• whether trading was economically rational;
• whether transactions created artificial volume;
• price impact;
• market liquidity;
• statistical anomalies;
• trading patterns;
• causation;
• valuation;
• investor loss.

In a manipulation claim, expert evidence can therefore be important in connecting:

transaction → artificial effect → investor reaction → financial loss.

27. Injunctions

An injunction can be particularly important where the claimant fears that assets or securities will be dissipated.

The Larmag litigation demonstrates the availability of interim protective measures in a financial dispute involving bonds. The DIFC Court restrained dealings with the relevant bonds while the dispute proceeded.

Possible objectives include:

• preventing asset disposal;
• preserving securities;
• preventing further misconduct;
• maintaining the status quo;
• protecting the eventual effectiveness of a judgment.

28. Disclosure of Trader Identity

A market-misconduct victim may know:

“Someone manipulated the market.”

but not:

“Who placed the trades?”

This creates a major evidentiary problem.

The Emirates REIT case is valuable because the applicants sought information from Nasdaq Dubai concerning the identity of clients who had placed the suspicious trades.

The Court recognised the good arguable case of manipulation but ultimately considered the applicants' proposed compensation claims insufficiently strong to justify the requested disclosure in the circumstances.

This illustrates that:

A claimant's right to investigate suspected wrongdoing must still satisfy procedural requirements for disclosure.

29. Loss Calculation

Potential approaches to damages may include:

A. Artificial-price difference

Difference between:

actual transaction price

and

hypothetical unaffected price.

B. Transaction loss

Actual financial loss attributable to the misconduct.

C. Overpayment

Amount by which the investor allegedly overpaid because of artificial price inflation.

D. Lost opportunity

Potentially relevant in appropriate circumstances, although it presents substantial causation and proof issues.

E. Consequential loss

Additional loss caused by the misconduct, subject to applicable legal requirements.

The exact measure depends upon the applicable cause of action and law.

30. Defences

A defendant may argue:

No manipulation

The trades were genuine.

Legitimate economic purpose

The transaction had a genuine commercial reason.

No knowledge

The defendant did not know and could not reasonably have known that the conduct would produce the prohibited effect.

No causation

The claimant's loss resulted from independent market factors.

No recoverable damage

The claimant cannot prove legally compensable loss.

Intervening event

Another event caused the loss.

Lack of standing

The claimant may not have a legally recognised private cause of action.

31. Market Misconduct and Civil-Law Principles

General civil-law concepts can become relevant to market misconduct, including:

• wrongful conduct;
• fraud;
• abuse of rights;
• causation;
• compensation;
• good faith;
• unjust enrichment;
• contractual obligations.

However, the special securities legislation should be examined first where the conduct falls directly within a regulated market-abuse provision.

Thus:

Special financial-market law + general civil liability principles

often provide the appropriate analytical framework.

32. Difference Between Regulatory and Civil Claims

A regulator's finding of misconduct can be important evidence, but regulatory liability and private compensation are not automatically identical.

33. Mainland UAE vs DIFC vs ADGM

This distinction is essential.

Mainland UAE

Primarily involves:

• federal securities legislation;
• SCA regulations;
• UAE courts;
• commercial companies legislation;
• general civil law.

DIFC

Has its own:

• Markets Law;
• DFSA regulatory framework;
• Financial Markets Tribunal;
• DIFC Courts.

ADGM

Has its own financial-services and markets regime, including statutory provisions concerning market abuse. The ADGM Financial Services and Markets Regulations define market abuse to include insider dealing and other prohibited behaviour involving financial instruments.

Therefore, a case from the DIFC should not automatically be cited as a Federal Supreme Court precedent for mainland UAE law.

34. Private Civil Claim — Step-by-Step

A claimant should establish:

Step 1 — Identify the instrument

Is it:

• listed shares;
• bonds;
• derivatives;
• investment fund interests;
• crypto tokens;
• another regulated investment?

Step 2 — Identify the market

Is the transaction conducted through:

• UAE mainland market;
• Nasdaq Dubai;
• DIFC;
• ADGM;
• foreign market?

Step 3 — Identify misconduct

Was it:

• insider dealing;
• manipulation;
• false information;
• fraud;
• wash trading;
• front-running?

Step 4 — Identify responsible persons

Possible defendants include:

• trader;
• director;
• company;
• broker;
• intermediary;
• investment manager.

Step 5 — Establish causation

Connect the misconduct to the loss.

Step 6 — Quantify damages

Produce reliable valuation and financial evidence.

Step 7 — Seek interim relief if necessary

For example:

• injunction;
• asset preservation;
• disclosure.

35. Hypothetical Example

Suppose Company A's shares trade at AED 5.

A group of traders coordinates transactions that artificially push the price to AED 8.

An investor purchases 100,000 shares at AED 8.

The manipulation ends and the price returns to AED 5.

The investor's apparent loss is:

AED 300,000

But a court would still need to consider:

1. Was there legally prohibited manipulation?
2. Who participated?
3. Was the AED 8 price artificially created?
4. Did the investor purchase because of the artificial market?
5. Would the investor have purchased anyway?
6. What was the unaffected market price?
7. Were other market factors responsible for the fall?
8. What damages are legally recoverable?

This is why proof of manipulation alone does not automatically establish damages of AED 300,000.

36. Regulatory Compliance Framework

Financial institutions should maintain:

• surveillance systems;
• suspicious-order monitoring;
• insider lists;
• restricted lists;
• information barriers;
• employee dealing policies;
• disclosure controls;
• communications monitoring;
• escalation procedures;
• regulatory reporting procedures;
• record-retention systems.

The Al Ramz proceedings illustrate the importance of surveillance and reporting systems for regulated market participants.

37. Algorithmic Market Misconduct

Where trading is automated, liability becomes more complicated.

Suppose an algorithm repeatedly places and cancels orders.

Questions include:

• Who designed it?
• Who authorised it?
• Who monitored it?
• What was its purpose?
• Did the operator know its likely effect?
• Were warnings generated?
• Were controls sufficient?
• Was there human oversight?

The fact that:

“The algorithm did it”

does not necessarily answer the legal question of responsibility.

38. Digital Assets

The expansion of digital assets creates new forms of potential market misconduct:

• token-price manipulation;
• wash trading;
• artificial liquidity;
• coordinated trading;
• misleading token information;
• misuse of non-public token information.

The DIFC's statutory formulation is notable because Article 54 expressly covers conduct relating to Investments or Crypto Tokens.

The Gate Mena/Huobi litigation demonstrates the increasing role of DIFC courts in disputes involving digital assets, although that case should not be treated as a market-manipulation judgment.

39. Important Legal Distinction: Market Loss vs Market Misconduct

A falling investment price does not itself prove market misconduct.

Financial markets naturally involve:

• volatility;
• speculation;
• liquidity changes;
• information asymmetry;
• investor sentiment;
• macroeconomic events.

The claimant must establish the legally prohibited conduct and its connection with the claimed loss.

This is particularly consistent with the approach in Emirates REIT, where the Court accepted a good arguable case of potentially manipulative trading but found the evidence of resulting loss insufficient for the particular compensation theories advanced.

40. Key Legal Issues

A UAE market-misconduct case commonly raises these questions:

1. What instrument was traded?
2. Which market was involved?
3. Which regulator has jurisdiction?
4. What law applies?
5. Was there insider information?
6. Was there manipulation?
7. Was the price artificial?
8. Was the conduct intentional, reckless or negligent?
9. Did the defendant know or reasonably ought to have known?
10. Did the claimant suffer loss?
11. Did the misconduct cause that loss?
12. What evidence proves the trading pattern?
13. Can trader identities be disclosed?
14. Can an injunction be obtained?
15. What damages are available?

41. Short Case-Law Revision Table

42. Conclusion

UAE market misconduct claims sit at the intersection of civil law, securities regulation, corporate governance and financial-market enforcement.

The most important forms include:

• insider trading;
• market manipulation;
• wash trading;
• marking the close;
• false or misleading market information;
• fraudulent securities transactions;
• front-running;
• improper use of confidential information;
• regulatory failures by intermediaries.

The Emirates REIT v Nasdaq Dubai decision is especially significant because it demonstrates that conduct may have the characteristics of market manipulation while the claimant must separately establish a legally actionable loss and causation.

Al Ramz Capital v DFSA demonstrates the separate compliance responsibilities of regulated intermediaries, particularly regarding suspicious transactions and market-abuse reporting.

The broader UAE/DIFC jurisprudence demonstrates that market misconduct can generate several types of legal consequences:

Regulatory investigation → administrative sanction → civil claim → injunction/disclosure → damages or other remedies.

The central civil-law principle is therefore:

A claimant must establish not merely that market conduct was irregular or harmful, but that the conduct falls within a recognised prohibition or civil wrong and that the claimant's legally recoverable loss was caused by that conduct.

Final Revision Points

1. Market misconduct protects the integrity of financial markets.
2. Insider dealing and market manipulation are distinct forms of misconduct.
3. Wash trading can create a false appearance of market activity.
4. “Marking the close” may constitute market manipulation.
5. Article 54 of the DIFC Markets Law is a central DIFC market-manipulation provision.
6. Market misconduct can produce regulatory as well as civil consequences.
7. Brokers and recognised members may have independent surveillance/reporting obligations.
8. Proof of misconduct and proof of loss are separate requirements.
9. Causation is often the most difficult element of a private claim.
10. Injunctions can preserve securities or assets pending litigation.
11. Disclosure may be sought to identify unknown market participants, subject to procedural requirements.
12. Algorithmic and digital-asset trading creates new market-misconduct questions.
13. DIFC and ADGM market-abuse law must be distinguished from mainland UAE securities law.
14. DIFC case law should not automatically be treated as Federal Supreme Court precedent.
15. UAE market-misconduct law combines specialised financial regulation with general civil-law principles of fraud, causation, compensation and remedies.