On 12 November, BonelliErede hosted the event ‘Choosing Your Forum: The Foreign Investor’s Enforcement Toolkit’ as part of the 2025 edition of Dubai Arbitration Week, the annual gathering of international arbitration professionals from around the world.
With more than 140 events scheduled between 10 and 14 November and numerous sponsors taking part, this year’s edition is proving to be one of the best attended since its inception. This testifies to the growing relevance of arbitration as a dispute resolution method on the global stage.
BonelliErede’s event offered international investors practical guidance on defining their strategies for choosing forums or arbitral seats and enforcing foreign judgments and arbitral awards in the UAE. Speakers hailed from domestic and international courts and arbitral tribunals, and attendees included investors with established interests in the region. The session featured Andrea Carlevaris (partner and co-head of the firm’s international arbitration practice, Rome), Michela D’Avino (senior counsel, Milan) and Letizia Santin (associate, Dubai) alongside Marco Vacca, CCO & Senior Legal Counsel at ZMI Holdings; H.E. Justice Sapna Jhangiani, Judge of the DIFC Courts; Sherif Akl, Regional Director, Arbitration and ADR, Middle East at the ICC International Court of Arbitration; and Kristin Campbell-Wilson, former Executive Director at Abu Dhabi International Arbitration Centre (arbitrateAD).
Andrea Carlevaris commented: “In a context where legal forums are multiplying and enforcement remains the true litmus test, the choice between onshore courts, free zones such as the DIFC and ADGM, and arbitration courts is not just theoretical – it is decisive. Every jurisdiction offers potential, but it is only when enforceability is certain, proceedings are efficient, and international standards are met that rights turn into tangible remedies”.
The panel analysed the main differences between onshore, offshore and free-zone jurisdictions in the region, with a focus on the role of the Dubai International Financial Centre (DIFC) as a ‘conduit court’ for the enforcement of foreign judgments and arbitral awards.
Letizia Santin added: “When advising foreign investors, one of our main responsibilities is to guide them in choosing the most suitable forum for enforcement. The DIFC is certainly an enforcement-friendly jurisdiction whose approach is not constrained by territorial ties. This makes it an effective tool, especially compared to more restrictive jurisdictions. For UAE-based companies and clients, the DIFC represents a strategic gateway for the enforcement of awards and judgments in the region – and beyond”.
BonelliErede opened its Dubai office in 2017 to strengthen its presence in a region that is increasingly central to international investment. The team, led by managing partner Marco De Leo, advises international investors with interests in the Gulf area, multinationals, and key local players. Among the office’s active practice areas, international arbitration has shown steady growth, in tune with regional dynamics and the need for highly specialised and strategically driven dispute resolution tools.
Marco De Leo concluded: “In recent years, our Dubai office has experienced significant growth in response to the rising demand for high-quality legal services in the region. Our international arbitration practice, in particular, has become a core pillar of our operations – reflecting both the strategic importance of dispute resolution and the firm’s growing reputation in this field, including in this part of the world”.
