Polaris Briefing: Week 45 — oil loses a fifth of its price, ADGM’s court rules on NMC, and Washington flags about 140 UAE listings for secondary sanctions

This is the sixth numbered edition of the series, 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. Several threads from our last edition did not move this week — the Official Gazette dates of the e-invoicing penalty decision and of the FIU’s freezing regulation, the Land Department’s third quarter, the DFSA’s fund rules — and we say so where it matters. Alongside this edition our Corporate Counsel has written a separate opinion piece on four files from his week; it is linked at the foot of the page.

01After the deadline: four more e-invoicing providers, an FAQ that cites a repealed decision, and federal paper at five per centTax

What happened: The Ministry of Finance’s list of accredited e-invoicing service providers, issued under Ministerial Decision No. 168 of 2026, grew from 82 to 86 names on 5 November, five days after the appointment deadline for businesses with revenue of AED 50 million or more; there is still no pre-approved tier and no name was removed, and the Ministry issued no announcement with the change. On 2 November the Federal Tax Authority republished its e-invoicing page with 41 frequently asked questions. They settle several practical points: a business must use the same accredited provider for sending and receiving; each entity may hold one Peppol registration, keyed to its tax identification number; every member of a VAT group needs its own endpoint, while invoices carry the group’s TRN; a business that sells only to consumers must still appoint a provider if it receives business invoices; there is no cancellation, only credit notes; and no QR code is required. The same page is out of date on the law. Asked about penalties, it refers readers to Cabinet Decision No. 106 of 2025, which Cabinet Decision No. 173 of 2026 repealed, links the June version of the guidelines rather than version 2.0, cites neither of the two decisions published in October, and contradicts itself on whether a buyer may reject an e-invoice. The Official Gazette date of Decision No. 173, and so its in-force date, is still not visible on any official page we could open. The Authority published no news, guide, decision or public clarification in the week and said nothing about corporate-tax returns for years ended 31 January, which fell due on Saturday 31 October; its own notices move the excise deadline from Sunday 15 November to Monday 16 November and the VAT deadline from Saturday 28 November to Monday 30 November. The Ministry published the results of its 27 October auction on 31 October: AED 1.1 billion allotted against AED 4.54 billion of bids, a new T-Sukuk maturing on 29 October 2029 at 4.95 per cent and a tap of the 2031 T-Bond priced to yield 5.05 per cent, 19 and 26 basis points over Treasuries. The next auction is on 24 November. The Ministry also met an IMF mission on corporate-tax revenue and its issuance plan to 2032, without publishing figures.

Why it matters: The FAQ will be the first place most finance teams look, and on penalties it points to a decision that no longer exists. Decision No. 173 caps the cost of failing to implement at AED 50,000 in any twelve months; Decision No. 106 had no cap. A business that reads the FAQ will misjudge its exposure in one direction, and an adviser who quotes it will be wrong. The weekend practice in the Authority’s VAT and excise notices is helpful, but it has not been stated for corporate tax, where a late return is a fixed penalty. And five-year federal dirham paper at about five per cent is now the reference rate for idle cash and for pricing loans between related companies.

02ADGM’s court finds NMC’s founder and former chief executive liable, the DIFC Courts uphold the setting aside of a whole arbitration award, and the regulators write white papersRegulation

What happened: On 5 November Justice Sir Andrew Smith of the ADGM Court of First Instance handed down judgment in three linked matters arising from the collapse of NMC Health, cited as [2026] ADGMCFI 0027. The court found that Dr B.R. Shetty and Prasanth Manghat, the group’s former chief executive, “dishonestly and knowingly participated” in a fraud on the NMC group between 2 April 2012 and 9 April 2020, which included misappropriating assets, publishing misleading financial statements and hiding borrowings from the auditors. Both were held liable for fraudulent and wrongful trading under the ADGM Insolvency Regulations 2022, and the administrators also succeeded on their claims under the UAE Civil Code. The court set USD 5,397 million as the starting point for the contributions due for fraudulent trading; in Abu Dhabi Commercial Bank’s separate action, Mr Manghat was held liable under Articles 282 and 285 of the Civil Code and Article 84 of the Commercial Companies Law, with damages that include USD 1,022.293 million of outstanding liabilities. Final orders follow a further hearing. In the DIFC, Justice Pelling refused permission to appeal his August order setting aside a whole DIAC award for deciding matters outside the parties’ submissions and denying a fair hearing (Princeton v Persephone, 3 November), and the Chief Justice refused to reopen a Court of Appeal judgment in Al Mheiri v Cameron (2 November), describing the test as high. The DFSA published a discussion paper, “Scaling Tokenisation: The Road Ahead”, and the DIFC Courts proposed an open standard for resolving smart-contract disputes through an opt-in court oracle; neither is a rule or a consultation. The FSRA warned the public on 5 November about “Airo Capitals”, which falsely claimed ADGM authorisation, and authorised an Animoca Brands fund manager and Arab Bank Switzerland’s digital-asset adviser; J.P. Morgan opened a DFSA-regulated private-banking branch in the DIFC. The Central Bank set out its 2027 regulatory priorities to bank and insurer chief executives on 4 November — suitability, governance, cyber resilience, an anti-fraud centre and thematic reviews of banks’ digital-asset and AI activity — without publishing the document. ADGM’s consultations on fees and on business centres closed on 6 November; the DeFi consultation runs to 30 November. Nothing moved on the DFSA’s fund rules under CP173, on VTB Bank v Kuanyshev in the DIFC Court of Appeal, or on the Gazette date of the FIU’s freezing regulation, whose website now refuses automated access. One addition to our last edition: on 26 October the DFSA fined an individual, Gary Joseph Peters, USD 210,000 for misleading it and failing to produce documents.

Why it matters: The NMC judgment is the clearest statement yet that directors and senior managers of ADGM companies answer personally for trading on when they knew, or should have known, that the company could not pay its debts, and that the Civil Code claims run alongside the ADGM statutory ones. That is a question for every board of an ADGM holding company with borrowings, and for the people who sit on them as nominees. The DIFC decision on the DIAC award matters to anyone who expects to enforce an award there: a tribunal that decides a point neither party argued can lose the whole award, not just the offending part. And the Central Bank’s thematic reviews of digital assets and AI will reach company accounts through their banks’ questions in 2027.

03Oil loses a fifth of its price on deal talk and an election, Dubai has its best week of the year, and London raises ratesMarkets

What happened: The seven OPEC+ countries still cutting voluntarily, without the UAE, agreed on 1 November to keep December production at September’s required level and meet again on 29 November. Brent futures then fell for four sessions: from USD 111.84 on the morning of 2 November to USD 104.77 at that day’s settlement, by more than 8 per cent on 4 November after the US election, and to USD 93.65 early on 5 November, with WTI at USD 86.98; the falls were attributed to reports that Iran had approved talks with Washington and to the US President’s statement that no immediate strike was planned, as reported. The EIA’s Brent spot series, which last week stood above USD 120, read USD 107.03 on 3 November. The Dubai Financial Market index rose from 5,770.73 to 6,025.55 over the week, 4.42 per cent by our calculation, including 3.96 per cent on 4 November, and is now 0.36 per cent down for the year; Emaar ended the week at AED 12.50 and Emirates NBD at AED 31.60. The ten-year Treasury yield fell from 4.94 to 4.86 per cent. US payrolls rose 165,000 in October, unemployment was 4.1 per cent and average hourly earnings rose 0.4 per cent on the month. The Bank of England raised Bank Rate to 4 per cent by eight votes to one, with one member wanting half a point, noting that the conflict in the Middle East is in its ninth month; the Reserve Bank of Australia raised to 4.85 per cent. Gold recovered above USD 4,000 and rose about 4 per cent in the week to 6 November. The IMF began its Article IV consultation with the UAE on 4 November, to run to 17 November; the Central Bank’s release on the opening said growth “is projected to reach 1.6% in 2026, before accelerating to around 10% in 2027” without saying whose projection that is, and the IMF’s regional outlook page still carries no text, so the contraction of 3.9 per cent for 2026 that we have reported remains a press figure. Bank of China’s Dubai branch listed the first renminbi Yulan bond on Nasdaq Dubai, and TA’ZIZ closed AED 5.1 billion of project financing for two Ruwais plants.

Why it matters: A fall of this size in a week is a reminder that the price of oil now moves on headlines from Washington and Tehran rather than on supply, and that it can reverse as quickly; nothing has been signed and the Strait is still disrupted. For UAE companies the immediate effects are lower fuel and feedstock costs and a lower risk premium on Gulf assets, which is what the DFM priced. Rates are moving the other way: a strong US labour market keeps a December Fed rise in play, and with the Bank of England, the Bank of Canada and the Reserve Bank of Australia all raising within eight days, the global turn is towards tighter money. The growth figures for the UAE now differ by more than five points between sources, which matters to anyone who must cite one.

04A secondary-sanctions warning on about 140 UAE-addressed listings, red flags for falsely flagged ships, a crypto exchange cut off, and the FATF’s list without the UAEBanking

What happened: On 4 November OFAC added the line “Secondary sanctions risk: See Section 2 of E.O. 13902” to about 1,078 existing listings made under the Iran petroleum and petrochemical order; by our count of the published changes, about 143 carry a UAE address — individuals and companies in DMCC, Hamriyah Free Zone, Jebel Ali, Sharjah, Ras Al Khaimah, Ajman, Abu Dhabi and mainland Dubai. These are amendments to existing listings, not new designations, and no UAE-addressed person was newly designated in any OFAC action between 1 and 7 November. The same day Treasury designated an India-based network that sold false flags and fake certificates to Iranian shadow-fleet tankers, including a Singapore company presenting itself as Eswatini’s ship registry, and OFAC published an alert with red flags for insurers, trade-finance banks and maritime service providers: no flag or an unknown flag in maritime databases, an MMSI prefix that contradicts the declared flag, a registry that does not exist, and certificates that cannot be verified. On 5 November Treasury designated 41 entities and four individuals behind the Prince Group network and said its executives relied on “layers of offshore holding companies, foreign entities, nominee directors, and corporate service providers”, the second time in three weeks that it has named our industry. On 6 November FinCEN ordered US financial institutions to stop all transfers to and from the crypto exchange MEXC Global, which it said facilitated at least USD 16 billion of illicit flows, including Iran- and Russia-linked funds; the order takes effect 30 days after publication in the Federal Register. OFAC also designated eight Canadian money-service businesses that exchanged rials for crypto. US official texts on the FATF plenary of 26–30 October report four jurisdictions removed from the grey list — Bulgaria, Côte d’Ivoire, the Democratic Republic of the Congo and Monaco — no additions, an unchanged black list, and a new targeted review of jurisdictions with longstanding weaknesses in virtual-asset supervision; neither mentions the UAE or Georgia, and the FATF’s own site could not be read. FinCEN and the Fed withdrew their proposal to lower the threshold for cross-border wire data. ADIB’s rights began trading on 4 November under the symbol ADIBRI26, one right for every 34.14 shares at AED 16.45; trading ends on 16 November and subscription runs from 10 to 24 November. The UAE banks we expected this week had all reported in October, and the general licences we listed last week were not changed.

Why it matters: Written as banking access, not policy. The secondary-sanctions line tells every non-US bank in plain words that dealing with these listed parties can cost it access to the dollar, and it is now attached to more than a hundred UAE addresses in the free zones where our clients operate. Any trace of those names in a counterparty list, a vessel record or an ownership chain will be treated as a reason to exit. The false-flag alert gives banks a checklist they will apply to every tanker and every charter they finance. And Treasury’s repeated references to corporate service providers and nominee directors mean that banks will ask who administers a structure, and why each director holds the role, as a sanctions question.

05Emaar’s sales slow and it bids for its own developer, Abu Dhabi publishes its nine months while Dubai does not, and Satwa is rezonedProperty

What happened: Emaar Properties reported nine-month revenue of AED 37.5 billion, up 13 per cent, profit before tax of AED 19.8 billion, up 18 per cent, property sales of AED 34.7 billion and a backlog of AED 158.8 billion, down from AED 164.9 billion at the end of June. By our arithmetic from its half-year release, group sales in the third quarter were about AED 8.1 billion and Emaar Development’s about AED 3.8 billion; the developer itself said that sales “reflected a measured pace in response to evolving geopolitical dynamics”, and against the nine-month figures reported by the press a year ago, sales are down by roughly 43 per cent for the group and half for Emaar Development. The same day Emaar Properties made a cash offer of AED 15 a share for the shares of Emaar Development it does not own, 19.4 per cent above the 2 November close; the offer opened on 6 November and closes at 3 pm on 10 December, with the result on 11 December. The Abu Dhabi Real Estate Centre reported nine-month transactions of AED 171.26 billion across 38,483 deals, up 76.1 per cent in value, with sales of AED 119.33 billion, foreign investment in the investment zones of AED 86.11 billion and AED 17.22 billion from non-resident individuals, against AED 8.2 billion in all of 2025; brokers now face a mandatory new licensing course. The Dubai Land Department still has not published a third-quarter or nine-month figure; its only release of the week moved Ejari onto the DubaiNow app, with contracts created, renewed and cancelled through UAE PASS, the certificate issued at once and the DEWA deposit paid in the same journey. Dubai Municipality rezoned Al Satwa on 1 November: plots of 1,000 square metres or more, including consolidated plots, may now build a ground floor and eight residential floors at a floor-area ratio of up to 3.5. Union Properties reported nine-month revenue of AED 809.5 million and profit of AED 28 million, as reported. Ras Al Khaimah Municipality had not uploaded its October report.

Why it matters: Emaar’s numbers are the first hard evidence from Dubai’s largest developer that off-plan sales slowed sharply in the third quarter, even as profits recognised from earlier sales keep rising; that gap is what buyers on payment plans should watch. The buyout takes Dubai’s main listed read on the off-plan market private and gives every holder of Emaar Development shares, including holding companies and foundations, a decision to make by 10 December. Abu Dhabi now publishes what Dubai does not, and its figures show non-resident money moving there. And the Satwa rezoning creates value for owners of adjacent plots who can assemble 1,000 square metres.

06A seafarer killed in the Gulf, an LNG carrier struck despite Iran’s consent, limited US strikes and talk of a deal, and northern beaches still closedRegion

What happened: Attacks on shipping continued through the week of the US election. The Joint Maritime Information Center recorded four attacks in the Strait off Musandam between 1 and 3 November and two in the Gulf, as reported; on 4 November UKMTO reported a tanker hit by two projectiles about 50 nautical miles north of Madinat ash-Shamal in Qatar, and on 5 November a seafarer was killed on the Marshall Islands-flagged tanker Velos Sapphire, which its owner said was hit by a likely projectile, as reported. Iranian forces claimed that several tankers and a tug caught fire after striking mines on 5 and 6 November; owners’ accounts differ, and the causes are contested. On 30 October Nakilat’s LNG carrier Al Mayeda was struck by unidentified objects in the Gulf; no crew were hurt. The press reported that its passage had been agreed with Iran through Pakistan, and on 2 November the UAE Ministry of Foreign Affairs condemned the attack as “a dangerous escalation”. A US official confirmed limited strikes in the Strait area around 2 and 3 November, the US President said a deal “could happen” and later that talks were “going well”, and Iran said the Strait would not reopen until its conditions were met, all as reported; Sheikh Abdullah bin Zayed spoke to Iran’s foreign minister on 5 November and stressed de-escalation. About 31 ships a day were transiting with US assistance, as reported. Inside UAE waters, no official update on the GEM NO. 2 spill followed the 30 October statement that the leak had stopped, and beaches in Sharjah, Ras Al Khaimah and Umm Al Quwain were still closed on 6 November, as reported. The Houthis claimed a missile strike on Riyadh’s King Khalid airport on 4 November, which Saudi Arabia has not confirmed. EASA’s bulletins for the Gulf, Saudi Arabia, Iran, Iraq, Jordan and Lebanon run unchanged to 16 November; Lufthansa Group plans to resume Dubai from 25 November. On trade, the UAE’s CEPA with the Democratic Republic of the Congo entered into force on 30 October, confirmed by WAM, while the Canada and Benin agreements are signed but not in force; ADIPEC closed with a claimed USD 67 billion of agreements, and ADNOC agreed to supply Gujarat Energy with up to 4 million tonnes of LNG over ten years from 2028.

Why it matters: Written as commercial execution risk: the attack on a carrier whose passage had reportedly been agreed with Iran shows that permission-based transit cannot be planned on or insured against, and a death on a ship sailing empty to Bahrain shows that the risk now covers the whole Gulf, not only the Strait. The promised escalation after the US election has not come, and neither has a deal; both remain possible within days. For coastal businesses in the northern emirates the spill is now in its third week with no reopening date. And the DRC agreement is the only one of the three new CEPAs that UAE exporters can use today.

07Georgia: Brussels finds no beneficial-ownership register, inflation reaches 5.9 per cent, and a new electronic act for purchases from individualsCorridor

What happened: The European Commission’s Georgia 2026 Report of 4 November says the country’s accession process “remains halted”. It notes Georgia’s November 2025 amendments to its AML law and the National Bank’s new supervision guidelines, but states that “Georgia still does not have a beneficial ownership register”, flags crypto as a growing challenge, puts alignment with EU sanctions and foreign-policy statements at 38 per cent, down from 40, records the EU’s listing of three Georgia-based crypto-asset providers and a transaction ban on the Kulevi refinery after a six-month wind-down, and criticises Georgia’s rule admitting nationals of 17 visa-required countries on the strength of a visa or residence permit from a GCC state, the UAE included. The National Bank’s own summary on 7 November quoted the positive findings — record reserves of USD 8.1 billion, non-performing loans of 2.6 per cent, capital adequacy of 22.2 per cent — and did not mention the register or the sanctions figure. Geostat put October inflation at 5.9 per cent, 0.9 per cent on the month, above the National Bank’s 5.4 per cent forecast, with transport up 21.9 per cent and rents up 12.8 per cent. The Revenue Service announced that from 1 December a business buying goods from an individual must issue an electronic purchase act on its portal, confirmed by the seller by SMS or online, and that only the electronic act will support the expense deduction; from 1 November corrected VAT and advance invoices must show the VAT difference on dedicated lines. It reminded taxpayers that property tax for individuals and land tax for companies must be paid by 16 November. The Enforcement Police, an armed unit of the National Enforcement Bureau that private enforcers may hire, began work on 1 November. A new law creates a permit for international gambling tournaments, with foreign winners exempt from tax where the prize fund exceeds GEL 3 million. Customs at Kazbegi recorded 49 cases of undeclared cash in a month, GEL 3.8 million in total, with fines of GEL 328,428. Fitch revised Georgia’s outlook to positive on 31 October. The lari ended the week at 2.5949 to the dollar and 0.7065 to the dirham at the official rate for 7 November.

Why it matters: The Commission’s report is the text that EU banks and correspondents will read when they assess a Georgian company owned through a UAE structure, and its two findings — no beneficial-ownership register and weak sanctions alignment — are exactly the questions they will ask. The GCC entry route that many UAE residents use is now under open pressure from Brussels. Inflation above the forecast makes a rate cut in December unlikely. And Georgian subsidiaries that buy from individuals lose the deduction for those costs from 1 December unless they change their process.

08The diary for Week 46Week ahead