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.

Chapter 15 of the Bankruptcy Code is designed to provide an effective mechanism to aid insolvency proceedings in foreign countries that involve a foreign debtor with assets, creditors and other parties in interest located in the foreign country as well as in United States. A foreign representative that is authorized to administer the foreign reorganization or liquidation or act as a representative of the foreign proceeding is the party who applies to the US bankruptcy court for recognition of the foreign proceeding.

Senior Transeastern Lenders v. Official Comm. Of Unsecured Creditors of TOUSA, Inc. (In re TOUSA, Inc.), 2012 US App. LEXIS 9796 (11th Cir. May 15, 2012)