Abstract
The United Arab Emirates (UAE) is experiencing rapid economic growth. The Emirate of Dubai has been especially active in the UAE's attempts to attract foreign capital. A key feature of Dubai's strategy has been to set up special trade zones. These special zones have their own rules and laws. The latest (and arguably, the most ambitious) zone is the Dubai International Finance Centre (DIFC). The DIFC has its own courts and judicial system. In 2004, the DIFC passed its own arbitration law. This law is now in the final stages of revision and a new DIFC Arbitration Law (DIFCAL) is expected to be promulgated soon. The new DIFCAL adopts (and adds to) the United National Commission on International Trade Law (UNCITRAL) Model Law on International Commercial Arbitration (1985). This commentary is intended to explain the operation of the 'Model Law Plus' provisions of the draft law.
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