Another AIFC judgment, and once again the issue concerns the competence of the AIFC Court to enforce foreign arbitral awards. The judgment demonstrates that there is ongoing debate on this issue, but it appears to take a firm position that the AIFC Court has no jurisdiction over the recognition and enforcement of foreign arbitral awards.

Paragraph 4.14 appears particularly important for understanding the point:

When parties agree to arbitrate under the auspices of any other institution (for example, the ICC, as in the present case) or agree to an ad hoc arbitration, they do not thereby agree to accept the jurisdiction of the AIFC Court. 

See: Judgment dated 27 May 2026 in Case No. AIFC-C/CFI/2025/0066 (link).

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