New York Times on Dubai Financial Laws

The laws in the UAE are remarkably similar, qualitatively, to the laws in the West; the differences are quantitative. In the West, if one buys something on credit, one signs a note, and, if the debtor fails to make the payments, the creditor might send someone to repossess, or might ask the courts to garnish the debtor's wages. But this is civil law, so debtors cannot be gaoled just for debt. And, as I understand it, neither must one necessarily be gaoled just for debt in the UAE.

In the West, if one knowingly writes a bad cheque, that's fraud, and one can be gaoled for fraud under the criminal law.

In Dubai, if one borrows money, the lender always demands a post-dated cheque, and, if one fails to repay, the cheque is used as proof of criminal fraud and the debtor/bad-cheque-fraudster goes to gaol.

So the laws in the West and in the UAE look similar, but in practice debtors who cannot pay usually do not go to gaol in the West, and generally do go to gaol in Dubai.

The New York Times writes that debtors in Dubai go to prison, unlike in the US where writing a fraudulent cheque is a civil offence which cannot possibly result in criminal penalties such as imprisonment. They find this terrible, and think Dubai must modernise and implement the New York City criminal and civil code.

The problem is that, on paper, the UAE laws look very similar to New York City laws: people must dress modestly in public; fraud is illegal; the rights of immigrant workers on H1 visas are similar.

But 'modest dress' has a different meaning; debtors are forced to write post-dated cheques in the UAE; and workers on H1 visas are less than 1% of US residents, but more than 80% of Dubai residents, so, as I said, the laws are qualitatively similar but quantitatively, drastically different.