Short answer
- UK buyers who paid the developer, not the escrow account, in Dubai should know that under Law No. 8 of 2007 off-plan buyer payments go into an escrow account opened in the project's name, and those deposits cannot be seized by the developer's creditors (Article 9(1)).
- In June 2024, RERA's Real Estate Control Department urged investors not to make any payments outside a project's escrow account.
- The law sets criminal penalties, with fines of at least AED 100,000, for misappropriating development money, but no stand-alone offence of "receiving money outside escrow".
- A transfer from a UK bank to a Dubai account is outside the UK APP reimbursement scheme; ask your bank for a SWIFT recall at once, knowing it needs the recipient's cooperation.
The bank details came on a letterhead or in an email, the transfer went through, and now you know it was not the project's escrow account. You have two jobs: secure what you can, and build a clear record.
Paid the developer, not the escrow account, in Dubai: why does it matter to UK buyers?
The escrow account is the one place Dubai law ring-fences buyer money; a developer's general account does not carry the same status.
Escrow in Dubai means a bank account opened in a project's name, under a written agreement between the developer and a RERA-approved escrow agent. Article 7 of Law No. 8 of 2007 directs off-plan buyers' payments there; Article 9(1) says the account serves only that project and cannot be seized by the developer's creditors.
…there is no escrow account for the project.
That reader's project was outside Dubai, but the escrow question is identical.
- Creditor protection
- Ring-fenced
- Article 9(1)
- Minimum fine, Art. 16 offences
- AED 100,000
- No maximum set
- UK APP scheme
- Domestic only
- International payments excluded
Is a payment not in escrow in Dubai a crime?
Not as a named offence. The English text of Law No. 8 of 2007 has no stand-alone offence of receiving money outside escrow; such conduct would be assessed under Article 16(4), which covers stealing, misappropriating or forfeiting money handed over for development, or under other laws.
What should I do first, from the UK, today?
Start with your bank, where time matters most.
Call your UK bank
Report the payment, ask for a SWIFT recall and get a reference number. Wise notes recalls are not guaranteed, need the recipient's explicit acceptance and can take several weeks.Report suspected fraud
If you believe you were deceived, report to Report Fraud on 0300 123 2040 or at reportfraud.police.uk; in Scotland, Police Scotland on 101.Pin down the real escrow number
Find the project in the DLD's Dubai REST app, which shows the escrow account number, and screenshot it with the date.Ask the developer in writing
Request written confirmation of where your money is now and whether it will be credited to the project escrow account, with a date.Take legal advice in Dubai
Bring the file to a UAE-qualified lawyer; disputes go to DLD settlement, the Dubai Courts or arbitration under your SPA.
Will my UK bank refund a wrong-account off-plan payment?
Probably not under the reimbursement rules. The APP scheme, in force since 7 October 2024, covers UK-to-UK payments sent by Faster Payments or CHAPS, capped at £85,000, and Which? confirms international payments are excluded.
Can the money still reach the escrow account?
Possibly, if the developer agrees to move it. Ask for the credit in writing, then check: Article 12 of Law No. 8 of 2007 lets depositors or their representatives see their own accounting records in the escrow account and request copies.
Example: a hypothetical £20,000 instalment went to a developer's operating account. A written commitment plus a copy of your escrow record showing the credit would close the gap; a verbal promise would not.
How should I manage the time difference while this is live?
Dubai is on UTC+4 all year: 3 hours ahead of the UK under BST and 4 hours ahead under GMT, which returns on 25 October 2026. Send emails to Dubai before about 10am UK time.
Wrong-account evidence file
Compare the account you paid with the registry record before your next message to the developer. Before any further payment, read the UK guide to verifying the escrow account; if the money was handed over in cash, see paying cash for Dubai off-plan, for British buyers. The global guide to payments outside escrow and the UK buyers' hub give the wider view.
What should I do about a payment not in escrow in Dubai, from the UK?
Can UK investors recover a wrong-account off-plan payment?
Is it illegal for a Dubai developer to take money outside escrow?
Why does Dubai escrow matter if the developer still has my money?
Can I see whether my money reached the Dubai escrow account?
Related guides
- GuidePaid the developer, not the escrow account, in Dubai: what to do now
- Country hubDubai off-plan problems for UK buyers: a guide to every stage
- UK guideHow to verify the escrow account for Dubai off-plan from the UK
- UK guidePaid cash for off-plan property in Dubai: what British buyers should check now
Sources
- Law No. 8 of 2007 Concerning Escrow Accounts for Real Estate Development in Dubai (Dubai Legislation Portal)
- Dubai developers fined for off-plan sales violations (AGBI)
- Dubai REST (Dubai Land Department)
- APP fraud reimbursement protections (Payment Systems Regulator)
- Amend, trace and recall payments (Wise partner docs)
- Report Fraud (City of London Police)
This guide is general information, not legal advice. Laws and procedures change; check the official source before acting. Published 12 October 2026, last updated 12 October 2026.