Polaris Briefing: Week 41 — Pillar Two gets a deadline, Washington names nine more UAE companies, and the tanker attacks reach UAE waters

This is the third numbered edition of the series we publish every Saturday: the week as it looked from a firm that forms companies, keeps them compliant and puts them in front of banks across the UAE, Georgia, Cyprus and Switzerland. The selection is ours; the facts are the regulators’. Where a rule, a date or a figure appears below it is taken from the issuing authority and linked at the end. Where we rely on market reporting we say so and name the source, because reporting is not a regulation and should not be filed as one. Alongside this edition our Corporate Counsel has written a separate opinion piece on a file that crossed his desk this week and on where a company’s money should sit in a year like this; it is linked at the foot of the page.

01Pillar Two gets a registration deadline, and the e-invoicing accreditation rules are rewritten eight days after they took effectTax

What happened: On 9 October the Ministry of Finance announced Ministerial Decision No. 168 of 2026 on the eligibility criteria and accreditation procedure for e-invoicing service providers. The Decision repeals Ministerial Decision No. 64 of 2025 and its amendments, including No. 56 of 2026, and states that it is effective from 1 October — eight days before it was announced. The pre-approval stage is abolished: a provider must now complete assessment and testing before it is accredited, accreditation lasts two years, and the Ministry keeps a central register of accredited providers and the businesses they onboard. Eligibility includes Peppol certification, a product in operation for at least two years, UAE incorporation or a UAE licence with paid-up capital of at least AED 50,000, ISO 22301 and ISO/IEC 27001 certification, insurance with UAE insurers (professional indemnity of AED 2.5 million and crime and cyber-fraud cover of AED 5 million each) and a commitment to provide one hundred free invoice exchanges a year to each end user. Providers holding pre-approval under the old Decision have thirty days from the effective date — by our reading, until 31 October — to complete accreditation or lose their status. The Ministry’s list stood at 65 accredited providers and five pre-approved ones on 8 October, and the deadline for businesses with revenue of AED 50 million or more to appoint one remains 30 October 2026 under Ministerial Decision No. 66 of 2026, with go-live on 1 January 2027. On 7 October, posted the following day, the Federal Tax Authority formally announced its Top-up Tax Guide on Scope and Registration (TTGREG1), the first guide on the 15 per cent domestic minimum top-up tax that applies to UAE entities of multinational groups with consolidated revenue of EUR 750 million or more in two of the previous four financial years, for financial years beginning on or after 1 January 2025. The guide fixes the first registration deadline: an in-scope entity whose financial year ended before 30 April 2026 must apply on EmaraTax by 30 November 2026 under FTA Decision No. 12 of 2026; later year-ends have seven months from the year end. Registration produces a separate Top-up Tax registration number, the penalty for failing to register is AED 10,000 per entity under Cabinet Decision No. 75 of 2023, a designated domestic filing entity may register a group’s UAE members together, and neither a corporate-tax exemption nor a free-zone 0 per cent rate takes an entity out of scope. The FTA published no new decisions or clarifications in the week, said nothing about how many corporate-tax returns were filed by 30 September, and announced no waiver; its only notices are the excise return due on 15 October and the VAT return due on 28 October.

Why it matters: Two deadlines now sit three weeks apart and both catch entities administered by firms like ours. Any UAE subsidiary, branch or free-zone vehicle whose ultimate parent consolidates EUR 750 million must register for Top-up Tax by 30 November if its 2025 year ended on 31 December, which is almost every group; the registration is separate from corporate tax and the 0 per cent free-zone rate is no defence. On e-invoicing, the AED 50 million test is applied per taxable person, so a single trading company inside a small group is caught on its own revenue, and a provider that is merely pre-approved on 1 November may no longer be allowed to serve it.

02ADGM fines an auditor and prices a late AML return at USD 3,000; the DFSA shelves its token proposals and keeps the fund rules unpublishedRegulation

What happened: On 9 October the ADGM Registration Authority published decision notices imposing USD 65,000 on PKF Accountants and Business Advisers LLP and USD 35,000 on its registered audit principal for failings in the audit of a metals-trading group with USD 46 billion of revenue, USD 665 million of inventory and USD 8.1 billion of receivables for the year to 31 March 2024. The fraud-risk presumption was wrongly rebutted, there was no sufficient evidence for inventory held under bills of lading, no cut-off test and no expected-credit-loss evidence, and the file recorded physical verification of USD 115.4 million of metal “consisting of a few gold bars”, which the Authority calculated would have been about 1,090 kilograms of gold. It is the first published enforcement case since the Authority named audit quality among its 2026–27 priorities on 1 October. The same day the Financial Services Regulatory Authority issued Consultation Paper No. 6 of 2026 on its fees: the late-filing fee would double to USD 1,000 and be charged again on the eleventh and the twenty-first business day overdue, to a cap of USD 3,000 per filing before the matter goes to enforcement; the paper says this expressly covers AML returns by designated non-financial businesses, that extension requests must be made at least ten business days before the deadline, and that a fee once applied is unlikely to be waived. Application fees for multilateral and organised trading facilities would rise from USD 10,000 to USD 100,000. Comments close on 6 November and the changes are proposed from 1 January 2027. Earlier in the week the FSRA consulted on DeFi risk-management guidance (Consultation Paper No. 5, to 30 November) and the Registration Authority on new Strata Regulations for ADGM property, under which owners’ associations would gain legal personality and licensed managers (Consultation Paper No. 4, to 22 October); the FSRA licensed Capital Group and New Mountain Capital and warned the public about a firm calling itself Takeo Investments. In Dubai, the DFSA published its feedback statement on Consultation Paper 174 on 5 October: the prudential and credit-rating-agency changes stand, a redesigned form B110 now applies to all authorised firms, and the crypto and investment-token definitional proposals are “not proceeding at this time”. The final rules on the collective-investment regime (Consultation Paper 173) remained unpublished as of 10 October. The DIFC said its register now holds 1,409 foundations, up 67 per cent on the year, and Dubai’s Higher Committee for the Development of the Economic and Financial Sector put DIFC active companies above 10,000 and approved work on a Dubai Gold Strategy. VARA issued a circular on 6 October setting a seven-point minimum scope for proof-of-reserves audits and signed an intelligence-sharing memorandum with the UAE Financial Intelligence Unit. The DIFC Courts dismissed, on 5 October, an AED 5 million personal claim arising from a contract between two companies, holding that the DIFC jurisdiction clause bound the companies and not their owners, and that a shareholder cannot sue for his company’s loss (Dhawan v El Jaouhari, CFI 058/2024).

Why it matters: Abu Dhabi has moved from publishing priorities to acting on them within nine days, and the target was the audit file of a commodity trader, the kind of client whose inventory sits on bills of lading in three ports. For every ADGM company the message is that the auditor will now ask for stock counts and shipping documents, and that the annual AML return is about to carry a hard cost for lateness. The DFSA’s decision to park the token definitions removes a January 2027 change that DIFC firms were preparing for, and the fund rules remain a promise. The DIFC Courts judgment is the one to send to clients who sign contracts for their companies and assume the company’s claim is theirs.

03The Fed’s minutes point to another rise, Brent ends at USD 104.72, and Gulf equities post a third week of lossesMarkets

What happened: The minutes of the Federal Reserve’s 15–16 September meeting, released on 7 October, record that all participants supported the quarter-point increase to 3.75–4.00 per cent and that “most participants assessed that another increase in the target range for the federal funds rate would likely be appropriate by year end”, citing elevated inflation and disruptions to oil shipments from the Middle East. Governor Waller said in Istanbul on 8 October that further increases need not come at consecutive meetings; futures priced roughly a one-in-five chance of a move on 28 October and better than four-in-five odds of at least one more by December, as reported. The ISM services index for September showed prices paid at 74.0, the highest since July 2022, and the University of Michigan’s October survey put consumer sentiment at 46.3 with one-year inflation expectations at 4.7 per cent. The ten-year Treasury yield touched 5.31 per cent on Monday and closed the week at 5.24 per cent; the dollar index rose for a fourth week to about 102.3 and the euro hit a seventeen-month low near 1.116 on 5 October, as reported. The European Central Bank’s account of its September meeting, published on 8 October, confirms the quarter-point rise to 2.50 per cent and says the inflation outlook “had deteriorated”. Türkiye’s September inflation came in at 29.73 per cent, below 30 for the first time since 2021, and the Reserve Bank of India raised its repo rate to 5.50 per cent. In oil, the seven remaining OPEC+ producers met on 4 October and held November output at September levels, with the next meeting on 1 November; Saudi Aramco cut its November Arab Light price to Asia by USD 3 to a USD 5 discount, the widest since 2020, to offset freight; IEA members agreed on 7 October to accelerate the remaining 100 million barrels of the March stock release, diesel first; and the US Energy Information Administration raised its fourth-quarter Brent forecast to USD 105. Brent settled at USD 100.20 on Wednesday and USD 104.72 on Friday, up 2.4 per cent on the week, with WTI at USD 91.85; supertanker fixtures above USD 1 million a day were reported for loading in the Gulf of Oman. Gold fell to a two-month low of USD 4,114 on Wednesday and recovered to about USD 4,190 by Friday. The Dubai Financial Market General Index closed Friday at 5,818, a second weekly loss, and Abu Dhabi’s at 9,796, a third; Saudi Arabia’s index fell 1.6 per cent on Thursday, its largest one-day drop since March, and Qatar’s reached its lowest since June 2020, all as reported by Reuters. Kamco’s count of third-quarter GCC bond and sukuk issuance was USD 42.5 billion, down 17.5 per cent on the quarter; no UAE issuer priced in the week, the Ministry of Finance’s next dirham auction is on 27 October, and ADIB’s shareholders approved an AED 1.75 billion rights issue at AED 16.45 a share. Three-month EIBOR stood at 4.32 per cent at the end of September and the Central Bank’s base rate at 3.90 per cent.

Why it matters: The minutes settle the direction: dirham borrowers should plan for a base rate of 4.15 per cent by the end of the year, not for relief. A ten-year above 5.2 per cent and a dollar near an eighteen-month high make dollar and dirham cash the best-paid it has been in a generation, and make every euro, lari and lira asset cheaper in dirham terms. Equity exits in the Gulf are closed for the quarter; the IPO pipeline is frozen and the indices are at multi-week lows. The freight numbers mean the oil price a UAE importer pays is well above the Brent print.

04Washington names nine UAE companies in a week: three designations, six in a draft rule, and a warning to every bankBanking

What happened: On 8 October the US Treasury and State Department added 27 companies, six individuals and 22 vessels to the sanctions list in an action against Iran’s shadow fleet. Three are UAE-based: ArabianPro Materials FZCO of Dubai, described as having exported USD 2 million of Iranian-origin petrochemicals in 2025; Hessonite Ship Management LLC of Deira, commercial manager of three Honduras-flagged tankers, one of which loaded Iranian petroleum products on at least eight occasions this year; and Horizon Ship Management FZE of Ajman Free Zone, manager of a gas carrier that loaded Iranian cargo at least three times. Two Mumbai firms, three Turkish companies and entities in Hong Kong, China, the Marshall Islands and the United Kingdom complete the network, and a wind-down licence for the Indian customs broker runs to 23 October. Two container ships formerly linked to Dubai’s Marvise SMC DMCC were delisted after their sale to non-sanctioned operators; Marvise itself remains listed. Three days earlier, on 5 October, OFAC published a Notice to Foreign Financial Institutions Conducting Business with Iran, warning that banks which keep Iranian relationships “could be targeted at any time without advance notification” and citing the cut-off of US correspondent access for Banque Misr’s UAE branches as a precedent; FAQ 156 was amended to explain how a bank ends up on the list of prohibited correspondent accounts. The same day FinCEN’s proposed A7 rule was published in the Federal Register (91 FR 63208) with comments due by 4 November. It would bar US institutions from transmitting funds to or from “A7 Network Sub-Agents” and names six as examples, all UAE free-zone companies: Galadriel Trading FZCO, Gimli Trade LLC-FZ, Hydrofusion Resources FZ-LLC, Pearl Bridge, Power Sphere LLC-FZ and Sigizmund FZCO, described as Dubai-based traders in agricultural goods, energy commodities and electronics and a marketing consultancy. FinCEN says sub-agents processed more than USD 17 billion of dollar transactions between January 2025 and June 2026 and that payment instructions “often appear to have IP addresses in Dubai”. None of the six is on the sanctions list, and the full sub-agent list would be shared with banks through FinCEN’s secure portal rather than published. On 9 October OFAC issued General License 135 authorising the sale, delivery and import of Russian-origin diesel until 7 April 2027, after an agreement reported between Presidents Trump and Putin; the licence does not touch UK or EU prohibitions. The United Kingdom designated 38 Russia-related entries on 8 October, including crypto exchanges and payment platforms that processed A7 transactions, with correspondent-banking prohibitions attached; no UAE address appears. OFAC also settled with a California freight forwarder for USD 175,015 over a USD 5,950 shipment from a designated Chinese company that had changed its name but not its telephone number or e-mail address. At home, the Central Bank Governor met the chief executives of every bank on 5 October: loans up 18.8 per cent on the year to the end of August, deposits up 13 per cent, non-performing loans down to 2.6 per cent, and AED 15.9 billion of deferrals and fee waivers for 155,971 customers under the March resilience package, of which 849 companies took AED 10.7 billion and 6,441 small businesses AED 2.9 billion; the Governor put foreign reserves at USD 257 billion at the end of September. The UAE Financial Intelligence Unit and VARA signed an intelligence-sharing memorandum, ADGM’s Numou platform added Comera’s lending and payments for small businesses, and NEOPAY agreed to buy 65 per cent of noon payments. No final rule on Banque Misr UAE has been published; the comment period closed on 1 October.

Why it matters: Written as banking access, not policy: nine UAE company names in official US documents in one week is a number every compliance department in the country has noted, and six of them are ordinary-looking Dubai free-zone vehicles — an FZCO, two LLC-FZs, an FZ-LLC — of the kind formed by the hundred every month. The practical result is that a trading company with a non-resident owner, flows to or from Russia’s neighbours, or any Iranian-origin goods will face enhanced due diligence and payment holds now, before any rule is final, because US correspondents are pushing the non-public list down to UAE banks. The freight-forwarder settlement is the lesson in miniature: screening names is not enough; addresses, telephone numbers, e-mail addresses and vessel numbers must be screened too. The Central Bank’s figures say the banks have appetite and that 6,441 small businesses have already been granted deferrals; capacity exists for the right file.

05Dubai’s third quarter: sales value down by nearly half on the private counts, prices near a plateau, and a rulebook for shared housingProperty

What happened: The Dubai Land Department had not published third-quarter or September statistics by 10 October, so the week’s figures are private. Cavendish Maxwell put residential sales at about AED 72.6 billion across some 34,000 transactions, down 47 per cent in value and 38 per cent in number from a record third quarter of 2025, with off-plan taking 65 per cent of value; nine-month residential sales were AED 292 billion, down 27 per cent. Springfield Properties counted AED 90.62 billion across 36,738 residential and commercial transactions and fäm Properties AED 92.9 billion across 37,429; the definitions differ, so the totals do. S&P Global Ratings, in a 7 October credit FAQ reported in the press, said monthly transactions averaged 12,644 between March and September against 17,198 in January and February, put prices 5 to 15 per cent below end-2025 levels depending on the segment, expects the disruption to run into 2027, and notes that scheduled deliveries would raise the housing stock by about a fifth by 2028. ValuStrat’s September index gave the counterpoint: values rose 0.1 per cent on the month, which it calls insignificant, with 80 per cent of villa communities now stable, while the annual decline widened to 4.5 per cent (villas down 3.4 per cent, apartments down 6.4 per cent). Leasing is the strong side: 298,984 rental contracts were registered in the first nine months, up 6.8 per cent, and September’s 48,639 were up 22.6 per cent on August, according to DXBinteract data cited by fäm Properties; the Rental Disputes Centre said 2,350 amicable settlements worth AED 401 million were concluded this year at an average of six days each. On 7 October Dubai Municipality issued the planning and building requirements guide under Law No. 4 of 2026 on shared housing, which took effect on 8 September: buildings are designated for individual or family occupancy, each occupant needs at least five square metres of bedroom space, a shared-housing permit must be obtained through the Build in Dubai platform after Civil Defence and SIRA approvals, tenancy contracts are registered with the Land Department, which is linked to the permit data, more than 44 areas are approved, existing buildings have until 8 September 2027, and fines run from AED 500 to AED 500,000 per violation, doubling for repeats to AED 1 million. Nakheel launched Bay Estate at Dubai Islands and awarded a shoreline contract; Abu Dhabi closed its LIVEX exhibition with more than AED 150 billion of agreements and opened a portal through which investors can take government land and assets on musataha and lease terms; the ADGM Registration Authority consulted on new Strata Regulations for its real estate (item 02). Fitch affirmed Ras Al Khaimah at A+, removed the negative watch and now expects the emirate to grow 1.5 per cent this year rather than contract, as reported by WAM. The Central Bank’s base rate stays at 3.90 per cent and no bank announced a mortgage repricing in the week.

Why it matters: Volume has roughly halved and value has not yet followed; that is a market clearing slowly, at prices sellers still resist. A client whose foundation or company holds Dubai apartments should read S&P’s supply line as the risk and ValuStrat’s plateau as the hope, and should assume lenders will use the first. The shared-housing guide converts a law that was widely ignored into a permit, an inspection and a tenancy registration that can be refused; any company letting a villa or apartment to unrelated occupants now has a deadline and a fine schedule. Leasing strength is the good news for landlords who hold rather than flip.

06The tanker attacks reach UAE waters, Riyadh’s airport is hit, and the World Bank writes down the GulfRegion

What happened: The Joint Maritime Information Center logged the worst week of the war for shipping: at least twelve tankers attacked between 28 September and 7 October on Lloyd’s List’s count, the first strike inside the Gulf since 9 September (a tanker 51 nautical miles off Qatar on 7 October, one crew member injured), twelve crew injured on the Panama-flagged ON PEACE off Oman, a fire on a tanker about 40 kilometres off Fujairah on 8 October, and on 9 October a vessel struck by a projectile about 13 nautical miles west of Al Jazeera on the Ras Al Khaimah coast, according to UKMTO as reported; the IRGC said vessels using “unauthorised” routes would be “pursued and punished anywhere in the region”. The Strait remains rated severe and the Gulf and the Gulf of Oman moderate; US-facilitated transits ran at about thirty a day against a 2025 baseline of 138. On 8 October President Trump posted that the United States would not attack Iran before the 3 November midterm elections; Iran’s foreign minister said Tehran was reviewing Washington’s reply to its seven-day plan to reopen the Strait and would answer within days, and Qatar confirmed that messages still pass through Doha. In Saudi Arabia, Houthi missiles hit Abha and Riyadh airports on 6, 7 and 8 October, killing six people, among them a Saudia captain, and damaging an aircraft; Etihad and flydubai cancelled Riyadh rotations, Lufthansa suspended Riyadh to 16 October, and EASA’s bulletin on part of Saudi airspace runs to 16 November, as do its Gulf bulletins covering the Emirates flight information region; Wizz Air cancelled all its UAE flights for the winter season from 25 October. The World Bank’s October update projects the Middle East contracting 2.1 per cent in 2026 and the GCC 4.3 per cent, with the UAE at minus 1.6 per cent this year and plus 8 per cent in 2027 on the assumption that the Strait reopens gradually from the year end, Saudi Arabia at minus 2 per cent, Qatar at minus 20.9 per cent and Oman the only Gulf economy growing, as reported; the IMF’s Managing Director called the energy shock “large but contained” and noted Gulf crude exports above pre-war volumes thanks to rerouting through Yanbu and Fujairah. The UAE’s own numbers were firmer: the Federal Competitiveness and Statistics Centre put first-half GDP at AED 961.9 billion, up 0.4 per cent, with non-oil GDP up 1.8 per cent and financial services up 14.8 per cent, after a second quarter down 2.1 per cent; the September PMI held at 55.3, its highest in twenty months, with selling prices rising at the fastest pace since May 2011, and Dubai’s PMI reached 54.5. The UAE–EAEU economic partnership agreement entered into force on 6 October, the UAE–Belarus services agreement on 7 October, and UAE–Thailand CEPA negotiations concluded on 8 October, all per WAM. Egypt’s urban inflation eased to 13.9 per cent with the central bank meeting on 29 October; Türkiye’s central bank meets on 22 October; Saudi Arabia’s retail Sah sukuk paid 5 per cent in October and the Capital Market Authority’s margin-trading consultation closes on 27 October.

Why it matters: Written as commercial execution risk: war-risk underwriters and P&I clubs will now rate “UAE waters”, not “Hormuz transit”, and cargo at anchor off Fujairah, Khor Fakkan or the northern emirates carries the premium; charterers should expect it in the next fixture. The Saudi airport attacks shorten the business-travel map for a month and will appear in project insurance. The World Bank’s minus 1.6 per cent is the figure lenders and rating agencies will use for the UAE this quarter, while the domestic PMI says non-oil businesses are growing and passing costs through at a rate not seen in fifteen years; both are true, and a budget should reflect both. The trade agreements with the Eurasian Economic Union and Belarus will reduce tariffs for traders in those corridors and, in the same week as the A7 rule, will also draw the banks’ attention to them.

07Georgia: a GEL 572 million fine, a draft budget at 5 per cent growth, and a higher property-tax threshold for owners abroadCorridor

What happened: On 10 October the National Bank of Georgia confirmed a fine of GEL 572.1 million, about USD 220 million at the official rate, on Bitexchange LLC, a registered virtual-asset service provider operating self-service crypto kiosks; GEL 572.03 million of it relates to transactions carried out without customer identification, the rest to two unreported suspicious transactions, weak sanctions and PEP screening and incomplete information given to the inspectors. The Bank said it has inspected 51 supervised entities this year and penalised most of them. The Prosecutor General’s Office opened an investigation into a non-executive member of the Bank’s board over alleged participation in regulated businesses, following complaints and recordings submitted by the fined company; the board recused her unanimously on 9 October and the Bank said supervision of virtual-asset providers was not within her remit. Parliament’s committees heard the 2027 draft budget on 9 October: real growth of 5 per cent, a deficit of 2.5 per cent of GDP, government debt of 31.6 per cent of GDP, tax revenue of GEL 25.25 billion and no cut to the fuel excise. The World Bank meanwhile raised its 2026 growth forecast for Georgia to 7 per cent, with tourism cooling because of the Gulf conflict. Harmonised inflation was 5.1 per cent in September against 5.6 per cent on the national index, core inflation 3.5 per cent, reserves a record USD 8.17 billion as reported, and the lari closed the week at 2.6005 to the dollar and 0.7080 to the dirham, slightly firmer, ahead of the 21 October rate decision. For property owners, the Revenue Service confirmed that the family-income threshold for the individual property-tax exemption has risen from GEL 40,000 to GEL 100,000 for 2026; declarations are due by 2 November and payment by 16 November, and the Minister of Finance issued the new declaration form on 8 October (Order No. 318). The European Parliament called on 8 October, by 445 votes to 37, for sanctions on the ruling party’s leaders, the Commission’s enlargement package of 6 October omitted Georgia, EU foreign ministers take up Georgia on 12 October, and the Constitutional Court referred the claim to ban five opposition parties to its plenum. Russia suspended imports of wine, beer and mineral water from several leading Georgian producers on 10 October, as reported. The National Bank licensed a new private bank, Bank of Georgia signed USD 118 million of IFC facilities, Poti’s container volumes were up 9 per cent in nine months, a market study was launched for the Anaklia port railway, and average monthly earnings in 2025 were GEL 2,165, up 9.9 per cent.

Why it matters: The fine is the largest enforcement action anywhere in our footprint this year, and it was imposed for a procedural failure — identification per transaction — not for proven laundering; Georgian VASP registration is now a supervised licence in substance, and UAE compliance teams onboarding Georgian crypto or payment counterparties should treat it as one. The governance episode at the central bank will be read by correspondent banks, and the European Parliament’s call means Georgian politically exposed persons will be screened harder from this week. For the ordinary client with a Batumi apartment the news is good: a GEL 100,000 family-income threshold, about AED 141,000, takes many owners out of the declaration, and those still in it have until 2 November.

08The diary for Week 42Week ahead