This article discusses
recent court rulings that deal with the enforceability of a Dubai International
Financial Centre (DIFC)-London Court of International Arbitration (LCIA)
arbitration clause following the entry into force of Decree No. 34/2021. It
will be seen that the local UAE (United Arab Emirates) and the DIFC Courts take
a markedly different, more liberal approach when compared to the approach taken
by foreign courts, such as the courts of Louisiana and Singapore. Defaulting
DIFC-LCIA arbitration clauses to a Concerning the Dubai International
Arbitration Centre (DIAC) forum seriously undermines the concept of party
autonomy in arbitration, sufficiently so to raise concerns with an experienced,
international arbitration judiciary. Caution must be exercised by those who
wish to safeguard the enforceability of their arbitration obligation in a
non-DIAC forum.