Accountability: Does the Reach of the Hungarian State Extend to Dubai? Or What Can – and Cannot – Be Enforced in the United Arab Emirates

As a law firm of Hungarian origin with an international practice – established in Germany, active across multiple legal systems, and with a licensed legal advisory presence in the United Arab Emirates – we examined the issue of accountability not as a political slogan, but as a matter of enforceability in legal reality.

Public discourse often conflates the issuance of a final judicial decision with its enforceability abroad. In the case of the United Arab Emirates – including Dubai – this distinction is particularly stark: as a non-EU legal system, it does not automatically enforce Hungarian (or other European) court judgments and administrative decisions. Any potential enforcement requires a separate recognition procedure, subject to strict conditions that are far from mere formalities.

In public discourse, one often hears demands for “full accountability.” From a legal perspective, however, accountability is not a political slogan, but a question of jurisdiction, enforcement, and international law. For that very reason, it is justified to ask the uncomfortable yet necessary question: how far does the reach of the Hungarian state actually extend? And where do the limits of legal reality lie – for example, in Dubai?

Jurisdiction vs. Enforceability

There is a fundamental, yet often overlooked, distinction between a state that:

• establishes a legal violation,
• issues a final binding decision,
• and a state whose decision can actually be enforced abroad.

The United Arab Emirates is not a member of the European Union, is not part of the European enforcement cooperation mechanisms, and does not automatically enforce decisions of European – including Hungarian – authorities or courts.

The UAE as a “Safe Haven”? – A More Nuanced Legal View

The Emirates – and Dubai in particular – have, over recent decades, deliberately positioned themselves as an international financial and business hub. Part of this is a distinctive legal environment that:

• provides strong protection for assets lawfully registered under the local legal system,
• while not entirely excluding the recognition of foreign judgments.

The key word, however, is recognition. In the UAE, a foreign judgment is not automatically enforceable. Its recognition must be sought in separate proceedings, during which the Emirati court will examine, among other things, whether:

• the judgment violates Emirati public policy,
• adequate procedural safeguards were observed,
• and whether there is a bilateral or multilateral basis for cooperation.

These are not mere formalities, but real legal filters.

What Does This Mean for Hungarian Accountability Efforts?

The legal reality is that:

• what is a final judgment in Hungary is not necessarily enforceable in Dubai;
• in cases involving offshore, holding, or trust structures, access to assets is especially complex;
• the paths of criminal liability and civil asset recovery diverge sharply.

This does not mean that “nothing can be done.” It does mean, however, that legal proceedings are:

• lengthy,
• costly,
• and far from guaranteed to succeed.

Why Is It Important to Speak About This Honestly?

The political promise of accountability becomes unconvincing if it fails to take into account the realities of international law. The legal toolkit is strong, but it is not omnipotent – and certainly not without territorial limits.

It would therefore be irresponsible to suggest that a change of government would, by itself, “bring home” assets located in the Emirates. The law is more complex than that.

The Minimum a Lawyer Owes: Facts, Not Illusions

As lawyers, we consider it important that public discourse be built not on reductive slogans, but on real legal possibilities and limitations. Accountability begins with a precise understanding of:

• what can legally be enforced in the UAE,
• what cannot, and
• which instruments are worth attempting at all, and over what time horizon.