Civil Law and UAE: Privatization of Essential Legal Functions

1. Introduction

Privatization of essential legal functions refers to the transfer or delegation of certain functions traditionally performed directly by courts, government departments, or public legal officers to:

private companies;

licensed professionals;

private notaries;

arbitration institutions;

mediation centres;

enforcement agents;

technology providers;

specialised service firms.

The important point is that privatization of a legal function does not necessarily mean privatization of sovereignty.

A private entity may be authorised to perform a limited procedural or administrative function while:

the State retains ultimate legal authority;

courts retain judicial supervision;

regulators retain disciplinary powers;

public-policy rules remain applicable;

the private provider remains subject to statutory duties.

This distinction is particularly important in the UAE because the country has developed several mechanisms through which private actors participate in functions traditionally associated with public legal institutions.

A major contemporary example is Dubai's Resolution No. 2 of 2026, which permits Dubai Courts to outsource specified enforcement procedures to authorised private establishments while retaining supervision by the competent execution judge and Execution Department.

2. Meaning of Privatization of Legal Functions

Traditional model:

State → Public Official → Legal Function

Modern UAE model:

State → Authorised Private Actor → Legal Function → State/Judicial Supervision

For example, instead of every enforcement activity being physically performed by a government enforcement officer, a court may outsource limited activities such as:

inventory of attached assets;

custody of attached property;

public auction of attached property;

transfer of possession.

The private enforcement agent does not become a judge.

The private company does not acquire general sovereign authority.

Rather:

A limited statutory function is delegated under governmental supervision.

3. Essential Legal Functions

The expression can cover several categories.

A. Notarisation

Dubai permits authorised Private Notaries Public to perform specified functions traditionally associated with government notaries.

These functions include:

registration of documents;

attestation of signatures;

date validation;

affidavits;

certain wills;

other functions assigned by law.

The private notary operates through a statutory authorisation and remains subject to court supervision.

B. Judicial Enforcement

Dubai's 2026 framework allows certain enforcement procedures to be outsourced to private establishments.

These include:

preparing inventories;

receiving and safeguarding attached assets;

selling attached property by public auction;

transferring possession;

other procedures specifically authorised.

The private enforcement agent exercises only the powers assigned under the enforcement framework and remains under the supervision of the competent judge and Execution Department.

C. Arbitration

Arbitration is another form of private dispute resolution.

Parties may choose a private arbitral tribunal instead of having the merits determined by a state court.

But arbitration does not mean that the State disappears from the process.

Courts continue to exercise functions concerning:

appointment in specified circumstances;

interim judicial assistance;

setting aside;

recognition;

enforcement;

public policy;

jurisdictional review.

Therefore:

Private adjudication operates inside a state-created legal framework.

D. Mediation and Conciliation

Mediation permits private or institutional neutrals to assist parties in resolving disputes.

The mediator does not ordinarily exercise sovereign judicial power.

The parties retain decision-making authority.

The court may subsequently become involved in:

approving settlements where required;

enforcing settlement instruments;

determining disputes about the settlement;

granting judicial assistance.

E. Legal Technology

Technology can increasingly perform functions formerly requiring direct government interaction.

Examples include:

electronic notarisation;

electronic filing;

digital service;

automated case management;

online enforcement procedures;

electronic auctions;

digital authentication.

Dubai's notary legislation expressly recognises an e-Notary Public, capable of performing specified functions without human intervention.

4. Privatization Does Not Mean Deregulation

This is the most important principle.

Privatization

means:

Private performance under public regulation.

Deregulation

means:

Removal or reduction of regulatory control.

The UAE model is generally closer to the first.

For example, a private notary is not simply a private person who decides independently to authenticate documents.

The person must:

satisfy statutory requirements;

be registered;

obtain authorisation;

follow prescribed procedures;

remain subject to supervision;

comply with disciplinary rules.

Dubai's Notaries Public legislation expressly establishes supervision, registration and disciplinary mechanisms for private notaries.

5. The Constitutional and Legal Boundary

Certain functions remain inherently connected with sovereign judicial authority.

A private actor cannot simply acquire unrestricted authority to:

determine criminal guilt;

impose criminal punishment;

issue final judicial judgments;

exercise unlimited coercive State power;

disregard procedural safeguards.

The State may delegate execution of defined administrative/procedural tasks, but it retains ultimate legal control.

Thus:

Delegation of execution ≠ delegation of sovereignty.

6. Dubai's 2026 Judicial-Enforcement Model

Resolution No. 2 of 2026 provides the clearest modern example.

Under the Resolution:

an authorised private establishment may receive outsourced enforcement work;

enforcement agents work for the private establishment;

the work is performed under the supervision of the competent execution judge;

the Execution Department audits and monitors the work;

complaints may be submitted against the establishment or enforcement agent;

enforcement agents must act impartially and with integrity;

confidentiality obligations apply;

agents cannot falsely represent themselves as government employees.

The Resolution expressly limits the outsourced functions to specified enforcement activities.

This is therefore controlled privatization, rather than complete privatization.

7. Why Enforcement Can Be Partly Privatized

Judicial enforcement can involve large amounts of administrative work.

For example:

identifying assets;

preparing inventories;

storing attached goods;

arranging auctions;

transferring possession.

These activities can be separated from the judicial decision itself.

The judge determines:

What may legally be enforced.

The authorised enforcement agent performs:

The specified operational steps.

This creates a functional division:

Judicial authority → Private operational execution → Judicial supervision

8. Private Notaries as an Earlier Example

Dubai's private-notary framework demonstrates that privatization of legal functions is not entirely new.

Under Dubai Law No. 4 of 2013:

private notaries can be registered;

authorised firms can provide notary services;

the courts retain supervisory functions;

the Notary Public Affairs Committee handles applications and complaints;

disciplinary mechanisms apply.

The law expressly allows certain government-notary functions to be assigned to private notaries.

The 2021 amendment further recognises government, private and electronic notary models.

9. E-Notary and Digital Privatization

Digitalisation creates a second level of privatization.

The legal function can be divided into:

Legal authority

and

technological performance.

An electronic system may:

verify identity;

process documents;

record transactions;

authenticate signatures;

generate official records.

But the legal validity of the process continues to depend upon the statutory framework.

Dubai's legislation expressly recognises an e-Notary Public performing specified functions electronically.

10. Case Law 1 — DNB Bank ASA v Gulf Eyadah Corporation & Gulf Navigation Holding PJSC [2015] DIFC CA 007

DIFC authority — not a mainland UAE precedent.

The DIFC Court of Appeal recognised and enforced an English judgment.

The case demonstrates an important aspect of modern UAE legal infrastructure:

A private party may use a specialised court system to obtain recognition and enforcement of a foreign judicial decision.

The DIFC's judicial system therefore interacts with private international commerce through a sophisticated enforcement structure.

Relevance to privatization

The case does not itself concern outsourcing to a private company.

Its importance is conceptual:

Legal enforcement increasingly operates through specialised, commercially oriented institutional mechanisms rather than exclusively through traditional domestic litigation.

11. Case Law 2 — Lural v Listran & Lokhan [2021] DIFC CA 003

DIFC authority.

The DIFC Court of Appeal considered the relationship between DIFC jurisdiction, foreign proceedings and contractual jurisdiction arrangements.

The Court emphasised the statutory independence of the DIFC judicial framework from the ordinary mainland UAE Civil Procedure Code.

Principle

Different legal institutions within the UAE may possess separately defined jurisdictional authority.

Relevance

This supports an important distinction:

Legal function can be institutionally specialised without ceasing to be legally regulated.

The DIFC model demonstrates institutional diversification rather than unregulated privatization.

12. Case Law 3 — Investment Group Private Limited v Standard Chartered Bank [2015] DIFC CA 004

DIFC authority.

The DIFC Court of Appeal considered the relationship between DIFC jurisdiction and non-DIFC UAE courts.

The Court recognised the special statutory position of the DIFC and the importance of the constitutional framework permitting financial free zones to operate under their own legal regimes.

Principle

The UAE legal system permits specialised institutional structures while maintaining their statutory boundaries.

Relevance to privatization

It illustrates the broader UAE trend toward:

specialised institutions;

delegated functions;

differentiated legal services;

institutional competition.

13. Case Law 4 — Nihan v Nicholas & Niaz [2024] DIFC CA 012

DIFC authority.

The case concerned arbitration and the argument that a dispute was not arbitrable because it involved public-policy considerations.

The DIFC Court of Appeal examined the relationship between:

arbitration;

public policy;

UAE law;

judicial supervision.

The judgment demonstrates that private arbitration does not eliminate the role of courts in determining the limits of private adjudication.

Principle

Private adjudication remains subject to mandatory legal limits and judicial supervision.

Relevance

This is directly relevant to the concept of privatization of adjudicative functions.

14. Case Law 5 — Egan & Eggert v Eava & Efa [2013] DIFC ARB 002

DIFC authority.

The case considered the relationship between arbitration, public policy and the judicial enforcement process.

The tribunal/court discussion recognised that the administration of justice and procedural safeguards may involve public-policy considerations in UAE law.

Principle

Private dispute resolution cannot completely displace the State's judicial enforcement role.

Relevance

The case demonstrates:

Private arbitration → judicial recognition/enforcement → public-law supervision.

This is a classic example of controlled privatization of a legal function.

15. Case Law 6 — Korek Telecom v Iraq Telecom [2024] DIFC CA 016

DIFC authority.

The DIFC Court of Appeal considered arbitration, foreign governmental acts, public policy and the limits of arbitral jurisdiction.

The Court distinguished:

arbitrability;

the merits of a claim;

public-policy questions;

judicial authority.

It emphasised that an issue affecting the success of a claim is not necessarily the same thing as an issue determining whether the dispute is arbitrable.

Principle

Private tribunals can determine many disputes, but their jurisdiction remains legally bounded.

Relevance

This illustrates the fundamental boundary of legal privatization:

Private actors can perform adjudicative functions only within authority granted by law.

16. Case Law 7 — General Assembly of the Dubai Court of Cassation, Case No. 10 of 2023

This important arbitration decision concerned the effect of a DIAC decision closing an arbitration file because arbitration costs had not been paid.

The General Assembly held that such closure did not amount to abandonment of the parties' arbitration agreement.

Principle

An institutional arbitration mechanism does not necessarily destroy the underlying private adjudicative agreement merely because an administrative event occurs within the arbitration process.

Relevance

It demonstrates judicial recognition of the institutional role of private dispute-resolution organisations.

The case therefore supports the proposition that private institutions may perform significant dispute-resolution functions while the courts retain ultimate supervisory jurisdiction.

17. Case Law 8 — Dubai Court of Cassation No. 828 of 2023

This case concerned incorporation of an arbitration clause from a main contract into subsequent purchase orders.

The Dubai Court of Cassation treated the arbitration agreement as applicable in the circumstances.

Principle

Private adjudicative authority arises from legally recognised consent and statutory arbitration rules.

Relevance

It shows that arbitration is not merely a contractual service.

Once legally validly constituted, it can produce consequences recognised and supervised by State courts.

18. Case Law 9 — YYY Limited v ZZZ Limited [2017] DIFC ARB 005

DIFC authority.

The case involved an arbitration agreement and disputes concerning court orders and the ability of parties to comply with them.

The judgment illustrates the practical interaction between:

private arbitration;

contractual rights;

court orders;

enforcement.

Principle

Private dispute resolution does not automatically eliminate judicial authority.

Relevance

It reinforces:

Private adjudication + public enforcement.

19. What These Cases Demonstrate

The cases collectively show that UAE law does not treat private performance of legal functions as an unrestricted transfer of sovereign authority.

Instead:

20. Public Function Versus Private Service

A crucial distinction is:

Public function

A function whose legal authority originates from the State.

Private service

A service supplied by a private entity.

A private entity may provide a service connected with a public function without becoming the holder of the sovereign function itself.

For example:

A private enforcement agent may conduct an authorised auction.

But:

The enforcement agent does not independently decide whether the debtor's property should legally be attached.

That decision remains within the judicial enforcement framework.

21. The Delegation Principle

The UAE model can be expressed as:

A-S-C

A = Authorisation

S = Supervision

C = Control

A private actor should perform a legal function only where:

Authorisation exists;

Supervision exists;

Control remains with the competent public authority.

This is particularly clear in Dubai's 2026 enforcement framework. The private establishment operates under a contract with the Courts, while the competent judge and Execution Department retain supervision.

22. Limits on Delegation

Not every public legal function can simply be transferred to a private company.

The stronger the connection with sovereign authority, the greater the need for statutory control.

Functions involving:

judicial determination;

criminal punishment;

coercive State power;

constitutional authority;

fundamental rights

require particularly strong legal safeguards.

A private actor cannot acquire such authority merely through a commercial contract.

23. Accountability of Private Legal-Service Providers

Privatization creates a new legal question:

Who is liable when a private provider performs a public legal function incorrectly?

The answer may involve several layers:

Private provider

Contractual and statutory responsibility.

Individual professional

Professional/disciplinary responsibility.

Regulator

Supervisory responsibility where legally applicable.

Court

Judicial review or correction.

Government

Responsibility where legislation specifically provides for it.

Dubai's private-notary legislation expressly provides that the authorised firm bears liability for faults committed by its private notaries, while the Courts are not automatically liable to third parties for damage arising from the firm's provision of notary services.

This is an important example of allocation of liability following privatization.

24. Independence and Impartiality

Privatization creates potential conflicts of interest.

A private company may have:

shareholders;

commercial incentives;

customers;

performance targets.

But legal functions require:

neutrality;

impartiality;

confidentiality;

integrity;

procedural fairness.

Dubai's 2026 enforcement rules therefore expressly require enforcement agents to act with impartiality and integrity and impose confidentiality obligations.

25. Confidentiality

Private legal-function providers may obtain sensitive information.

Examples include:

debtor assets;

bank information;

property records;

litigation documents;

personal data;

corporate information.

Privatization therefore requires strict confidentiality.

The 2026 Dubai enforcement framework expressly restricts disclosure of information concerning enforcement proceedings and attached property.

26. Digital Privatization

Digital legal services introduce another layer.

A private technology provider may operate:

identity-verification systems;

electronic document systems;

auction platforms;

digital filing infrastructure;

authentication technology.

But:

Technology cannot determine the legal validity of an act unless the legal framework gives it that effect.

The law must define:

authority;

authentication;

auditability;

security;

evidence;

correction;

liability.

Dubai's recognition of e-Notary illustrates this model.

27. Artificial Intelligence and Privatized Legal Functions

AI creates additional concerns.

Suppose a private company supplies an AI system used in:

enforcement;

document verification;

legal classification;

case management;

risk assessment.

The following questions arise:

Who owns the system?

Who supervises it?

Who is responsible for an error?

Can a person challenge an automated decision?

Can the system exercise coercive authority?

Is human review required?

How is confidential data protected?

The strongest legal principle is:

AI may assist a legal function, but statutory authority and accountability must remain clearly allocated.

28. Privatization and Access to Justice

Privatization can potentially improve:

speed;

accessibility;

technological efficiency;

specialised expertise;

availability of services;

administrative capacity.

But it can also create risks:

excessive costs;

unequal access;

commercial conflicts;

inconsistent practice;

reduced transparency;

accountability problems.

Therefore, the legal system must balance:

Efficiency

against

fairness and public accountability.

29. Privatization and Fundamental Rights

Essential legal functions often affect fundamental rights.

For example, enforcement can affect:

property;

possession;

privacy;

business operations.

Notarisation can affect:

ownership;

contractual rights;

succession;

corporate control.

Arbitration can affect:

access to courts;

binding dispute resolution;

enforcement rights.

Therefore:

The more a private function affects fundamental rights, the stronger the requirement for statutory safeguards and judicial supervision.

30. Privatization and Public Policy

Public policy remains a fundamental limitation.

A private legal service provider cannot contract out of:

mandatory law;

public-order requirements;

judicial safeguards;

statutory enforcement rules.

Similarly, an arbitration tribunal cannot enforce an award in a manner contrary to fundamental UAE public policy.

The DIFC arbitration authorities illustrate this relationship between private adjudication and public-policy review.

31. Privatization and Arbitration

Arbitration is perhaps the clearest example of privately performed adjudication.

The parties voluntarily transfer determination of their dispute from a State court to an arbitral tribunal.

Yet the State retains:

Before arbitration

support for constitution of the tribunal in appropriate cases.

During arbitration

interim judicial assistance where legally available.

After arbitration

setting-aside jurisdiction;

recognition;

enforcement.

Therefore:

Arbitration privatizes dispute determination, but not the entire enforcement system.

32. Privatization and Notarisation

Notarisation demonstrates another model.

Traditional

Government notary → authentication.

Modern Dubai model

Government notary / private notary / e-Notary → statutory authentication.

The private notary is not simply an ordinary commercial service provider.

The person must operate within a legally created system.

Dubai's legislation provides for registration, authorisation, supervision and disciplinary control.

33. Privatization and Judicial Enforcement

The 2026 Dubai model is even more significant.

The Courts may outsource defined enforcement procedures to a private establishment.

But the private establishment must:

employ qualified enforcement agents;

obtain the required licensing;

comply with court instructions;

maintain records;

submit reports;

permit inspection;

preserve confidentiality;

follow the orders of the competent judge.

The Execution Department can audit the establishment and investigate complaints.

This creates a model of:

Private execution + public supervision.

34. Why This Is Not Complete Privatization of Justice

Justice has at least three components:

1. Adjudication

Determining legal rights and liabilities.

2. Enforcement

Giving practical effect to the decision.

3. Administration

Managing files, assets, notices, auctions and records.

The UAE can permit private participation in administrative and limited enforcement functions without transferring ultimate adjudicative authority.

This distinction is essential.

35. Legal Personality and Delegated Authority

A private company performing a public legal function does not automatically become a government authority.

Its powers derive from:

statute;

regulation;

authorisation;

contract with the relevant authority;

judicial instructions.

Therefore:

Private legal authority is derivative, not inherent.

The company has no greater power than the law and authorisation provide.

36. Ultra Vires Acts

An enforcement agent or private notary acting beyond the authorised scope creates an ultra vires problem.

For example:

If an enforcement agent is authorised to sell attached property but independently decides which property may be attached, that decision may exceed the delegated authority.

The legal question becomes:

Did the private actor merely execute an authorised decision, or did it make a decision reserved to the public authority?

This is one of the most important legal boundaries.

37. Standard of Care

Privatization does not reduce professional responsibility.

A private legal-function provider should be expected to comply with:

statutory procedures;

professional standards;

confidentiality;

impartiality;

reasonable care;

recordkeeping;

technological safeguards.

Where negligence causes damage, civil liability may arise according to the applicable legal framework.

38. Judicial Review as the Safety Mechanism

The ultimate safeguard is judicial review or judicial supervision.

The private actor's decision or conduct may be challenged through:

grievance mechanisms;

regulatory complaints;

execution-court applications;

civil claims;

disciplinary proceedings;

judicial review where applicable.

The Dubai 2026 enforcement system expressly provides for complaints and supervisory inspection.

39. Economic Rationale

The UAE's privatization model is closely connected with economic modernisation.

Private participation may provide:

specialist expertise;

investment;

technological innovation;

operational flexibility;

lower administrative burden;

faster service delivery.

This is particularly useful in a rapidly growing commercial environment.

However:

Economic efficiency cannot replace legal accountability.

40. Public-Private Partnership Model

The legal-function model can be understood as a form of public-private partnership.

Government provides:

legal authority;

regulatory framework;

supervision;

enforcement power;

judicial control.

Private sector provides:

personnel;

technology;

operational capacity;

specialised services;

infrastructure.

Courts provide:

ultimate adjudicative authority;

legal oversight;

remedies;

enforcement supervision.

41. Comparison of Traditional and Modern Models

42. Six Core Case-Law Principles

The DIFC cases in this table are DIFC authorities, not binding precedents for mainland Dubai Courts. Their value here is principally comparative and illustrative.

43. Current Legislative Example — Dubai Private Notaries

Dubai's legislation expressly permits:

Private Notaries Public

to exercise certain functions of government notaries.

The system includes:

registration;

authorisation;

technical supervision;

disciplinary control;

complaints;

inspection;

firm-level responsibility.

This is a textbook example of controlled delegation of a public legal function.

44. Current Legislative Example — Private Judicial Enforcement

Resolution No. 2 of 2026 goes further by permitting outsourcing of specified enforcement procedures.

The private establishment may perform:

asset inventory;

custody;

auction;

transfer of possession.

But it must perform them according to the Federal Civil Procedure Law and under the authority of the competent execution judge.

This is one of the clearest contemporary examples of the UAE's movement toward regulated privatization of legal administration.

45. Legal Risks of Privatization

1. Conflict of interest

A private company may have commercial incentives.

2. Accountability

The claimant must know whom to sue or complain against.

3. Excess of authority

Private actors may exceed delegated powers.

4. Confidentiality

Sensitive legal information may be exposed.

5. Unequal access

Private fees may affect accessibility.

6. Procedural fairness

Affected persons must have meaningful opportunities to challenge improper conduct.

7. Data protection

Digital legal services process sensitive personal information.

8. Fragmentation

Different private providers may apply procedures inconsistently.

46. Safeguards Required

A sound privatization framework should contain:

L-S-A-R

L = Legal authority

S = Supervision

A = Accountability

R = Review

Thus:

No privatization of an essential legal function should occur without legal authority, supervision, accountability and review.

47. Practical Example

Suppose a Dubai court orders attachment and sale of a debtor's machinery.

Under the traditional model:

Court enforcement officer → inventory → custody → auction → transfer.

Under the modern outsourced model:

Court order → private authorised establishment → enforcement agent → inventory/custody/auction → report → Execution Department/judge supervision.

The private agent does not decide whether the attachment should exist.

The agent executes the authorised enforcement procedure.

Therefore:

Judicial decision remains public; operational execution may be private.

48. Another Example — Private Notary

A person wants to authenticate a document.

Traditional model

Government notary.

Modern model

Authorised private notary.

But the private notary must:

be registered;

operate through an authorised framework;

follow statutory procedures;

maintain records;

comply with supervision.

The resulting document receives its legal effect because the law recognises the private notary's authorised function, not merely because a private professional signed it.

49. Arbitration Example

Two companies agree to arbitration.

Private element

The arbitral tribunal determines the dispute.

Public element

The State:

recognises the arbitration agreement;

provides judicial assistance;

reviews specified challenges;

enforces the award.

Therefore:

Private adjudication is legally effective because the State's legal system recognises it.

50. Essential Legal Functions and Public Trust

Privatization must preserve confidence in the legal system.

A person interacting with:

a private notary;

enforcement agent;

arbitration institution;

electronic legal platform

must be able to trust that the actor:

possesses legitimate authority;

acts impartially;

protects confidential information;

follows statutory procedures;

remains accountable.

The private actor therefore performs a public-facing legal function without becoming a sovereign authority.

51. Relationship with the 2025 Civil Transactions Law

The new Federal Decree by Law No. 25 of 2025, effective from 1 June 2026, forms the current foundation of UAE civil transactions law. The Government describes the new law as part of the broader modernisation and consolidation of the UAE civil-law framework.

Its importance to privatization is indirect but significant.

Private legal-service providers increasingly operate through:

contracts;

professional obligations;

corporate structures;

liability rules;

statutory duties.

The new Civil Transactions Law therefore forms part of the wider private-law environment within which these providers operate.

52. Examination Distinction

Question:

Has UAE law privatized justice?

Correct answer:

Not completely.

A better formulation is:

UAE law permits regulated private participation and delegation in selected legal functions, including notarisation, arbitration, mediation and, increasingly, specified enforcement procedures, while retaining public authority, judicial supervision, statutory limits and public-policy safeguards.

53. Short Revision Table

54. Exam Formula

Remember:

A-S-C-R

A — Authorisation

S — Supervision

C — Control

R — Review

Therefore:

Privatized Legal Function = Authorisation + Supervision + Control + Review

55. One-Line Exam Answer

Privatization of essential legal functions in the UAE refers to the legally regulated participation of private actors in functions such as notarisation, arbitration, mediation and specified judicial-enforcement activities, while ultimate sovereign authority, statutory control, judicial supervision and public-policy safeguards remain with the State.

56. Conclusion

The UAE model is better described as regulated delegation rather than complete privatization of justice.

The development of private notaries, electronic notarisation, arbitration institutions and the 2026 outsourcing of specified judicial-enforcement procedures demonstrates a gradual shift from a purely government-operated model toward a public-private legal infrastructure.

The fundamental principle remains:

The State may permit private actors to perform defined legal functions, but private actors receive only the authority granted by law.

This produces a four-part structure:

Public Authority

creates the legal power.

Private Actor

performs the authorised function.

Regulator/Court

supervises the function.

Judiciary

provides ultimate legal review and enforcement.

The 2026 Dubai enforcement framework is particularly significant because it expressly permits private establishments to perform specified attachment, custody, auction and possession-transfer activities, but places those activities under the competent judge and Execution Department's supervision and auditing.

Thus, the modern UAE position can be remembered as:

“Private performance, public authority, judicial supervision.”