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Level Up: Unlocking Financial Potential In The Middle East
Welcome to this edition of Law Update, where we focus on the ever-evolving landscape of financial services regulation across the region. As the financial markets in the region continue to grow and diversify, this issue provides timely insights into the key regulatory developments shaping banking, investment, insolvency, and emerging technologies.
2025 is set to be a game-changer for the MENA region, with legal and regulatory shifts from 2024 continuing to reshape its economic landscape. Saudi Arabia, the UAE, Egypt, Iraq, Qatar, and Bahrain are all implementing groundbreaking reforms in sustainable financing, investment laws, labor regulations, and dispute resolution. As the region positions itself for deeper global integration, businesses must adapt to a rapidly evolving legal environment.
Our Eyes on 2025 publication provides essential insights and practical guidance on the key legal updates shaping the year ahead—equipping you with the knowledge to stay ahead in this dynamic market.
A complete spectrum of legal services across jurisdictions in the Middle East & North Africa.
UAE Federal Transport Authority Issues Rules on Ship Fuel
Pursuant to Circular No. 11 of 2019 dated 22 December 2019 (the “Circular”), the UAE Federal Transport Authority – Land & Maritime (the “Authority”) has instructed that as of 1 January 2020, all fuel oil on board any UAE and foreign-flagged vessel entering UAE territorial waters must not have sulphur content “exceeding 0.50% m/m” (the “Compliant Fuel“).
Further, from 1 March 2020, UAE and foreign-flagged vessels entering UAE territorial waters “without an approved alternate means of compliance (such as Exhaust Gas Cleaning System)”, are prohibited from carrying fuel oil that is not a Compliant Fuel, unless such fuel complies “with the required emission levels”.
Non-compliance
The Authority directed that from 1 January 2020, all vessels entering UAE territorial waters or calling UAE ports that carry fuel that is not a Compliant Fuel, must submit a Fuel Oil Non-Availability Report (“FONAR”) in the manner as follows:
| Vessel’s Flag | Manner of Submitting the FONAR |
| UAE |
|
| Others |
|
Clients are advised that submission of the FONAR does not exempt the respective vessel from the requirement to carry Compliant Fuel. In this regard, vessels entering UAE territorial waters are recommended to obtain and carry Compliant Fuel at the earliest opportunity.
The Authority also “strongly recommends” that the Master of the vessel “prepares a Letter of Protest addressed to the local authorities in the port(s) where compliant fuel oil was not available”.
Retention of documents
The Circular also contains instructions on retention of documents, which is as follows:
| Document / Item | Retention Instructions |
| FONAR |
|
| Bunker Delivery Note |
|
| Representative Sample
(MARPOL |
|
Final Remarks
The issuance of the Circular follows the International Maritime Organisation’s implementation of the 0.50% global sulphur cap for marine fuels, and will assist vessel owners and charterers to better plan their voyages to the UAE, a maritime and bunkering hub in the Middle East.
Both Omar Omar and Gabriel Yuen are available should you have any query on fuel oil compliance and charterparty negotiations.
Key Contacts:
Omar Omar
Partner, Head of Transport & Insurance – UAE
o.omar@tamimi.com
Gabriel Yuen
Associate, Transport & Insurance
g.yuen@tamimi.com
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