Payment Orders were originally introduced in the CPC as a fast track route for creditors holding a financial instrument, such as a letter of credit or cheque, to obtain judgment against their debtor for what is a simple and indisputable debt. Payment Orders were rarely issued by the onshore UAE courts. In 2018, Cabinet Resolution No 57 of 2018 (the “2018 Cabinet Resolution”) significantly expanded the scope of application of Payment Orders by extending them to all admitted debts rather than simply those arising out of financial instruments only.

It was only a matter of time. On January 12, 2021, the Department of Justice (“DOJ”) announced that it had reached its first civil settlement regarding allegations of fraud related to the Paycheck Protection Program (“PPP”).¹ DOJ settled a $4.2 million claim against a bankrupt internet retailer and its president for $100,000. Although unique to the case’s specific allegations, the settlement reveals activities that may be alleged as PPP fraud, statutes at DOJ’s disposal to pursue civil enforcement, and terms by which DOJ will resolve PPP fraud allegations.