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Deal by Design
Welcome to this edition of Law Update, focusing on the evolving M&A landscape across the MENA region. With deal activity and value continuing to grow, the region is seeing increased investor interest alongside a changing regulatory environment.
This edition explores key legal and market developments affecting M&A transactions, including regulatory reforms, foreign investment, governance, due diligence and deal structuring across the region.
Dubai Customs and DP World have now published the temporary framework for cargo destined to Jebel Ali Port and the Dubai free zones through Khorfakkan and Fujairah. Dubai Customs Notice No. (03/2026), issued on 8 March 2026, provides that containers may be moved by road directly from Khorfakkan or Fujairah to Jebel Ali Port and the Dubai free zones without first undergoing the regular customs clearance procedures at the port of arrival. Instead, the movement is to take place under secure bonded movement, with containers received into designated yard areas at Jebel Ali pending completion of the currently applicable customs procedures. The notice is expressly temporary and may be amended, suspended or withdrawn by Dubai Customs at any time.
DP World related guidance sets out the practical operating model. Under the published arrangement, containers may be discharged at Khorfakkan Port or Fujairah Port and then transferred by road under bonded trucking coordinated by DP World Logistics. The published guide states that the road transfer takes place under customs seal and in coordination with the relevant UAE authorities. It also makes clear that Jebel Ali remains the final port of operations; the bill of lading should continue to show Jebel Ali as the final destination; customs clearance, delivery order and terminal charge processes continue through Dubai Trade and the existing Jebel Ali procedures; and free time starts when the cargo arrives at Jebel Ali. Taken together, the published materials address import cargo, cargo for Dubai free zones, and transshipment containers intended for further processing at Jebel Ali.
DP World, in coordination with the relevant shipping line or its authorised agent, is responsible for the bonded transfer to Jebel Ali Port and the Dubai free zones and for ensuring manifest integration with Dubai Customs’ electronic systems. The shipping line or its authorised agent must submit the cargo manifest against the corresponding road rotation and issue delivery orders through Dubai Trade in accordance with the current procedures. The consignee or its authorised representative must process the customs declaration and complete final customs clearance before cargo release.
As a practical matter, the published process is framed as a DP World-coordinated bonded transit process initiated by the shipping line, rather than a standard post-discharge road leg following local customs clearance at Khorfakkan or Fujairah. Parties should therefore align their operational, documentation and payment steps to the published DP World and Dubai Customs process from the outset.
For operational support or tracking / transfer queries, parties may contact DP World Logistics at dpwuae.ss@dpworld.com. For general clarification, the published materials also refer parties to Jebel Ali Terminal Customer Care at +971 4 889 7797 and customerservice@dpworld.com.
Given the expressly temporary nature of this arrangement and the contingency context of the DP World process, market participants should continue to monitor further Dubai Customs, Dubai Trade and DP World circulars and ensure that shipping, broker, consignee and terminal-facing teams are all working from the same bonded-transfer workflow before cargo is discharged at Khorfakkan or Fujairah.
Our team at Al Tamimi & Company is advising carriers, shipping agents, cargo interests and logistics operators on the customs, operational, contractual and risk-allocation issues arising out of these temporary arrangements, including documentation flows, broker interfaces and coordination points with DP World, Dubai Trade and Dubai Customs.
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