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Deposits & cash · Q&A · For buyers in United Kingdom

Paid the developer, not the escrow account in Dubai: next steps for UK buyers

Paid the developer, not the escrow account, in Dubai? UK buyers: why it matters, what Dubai law says, and the SWIFT recall and Report Fraud steps to take.

By HomeProof Research TeamUpdated 6 min readDubai law · every fact with a source

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.

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.
an off-plan buyer writing to Gulf News' Ask the Law · Gulf News, Sept 2018

That reader's project was outside Dubai, but the escrow question is identical.

Where payments belong
Project escrow
Law No. 8 of 2007, Article 7
Source: dlp.dubai.gov.ae
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.

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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?
For a payment not in escrow in Dubai, ask your UK bank for a SWIFT recall straight away and get a reference. Report suspected fraud to Report Fraud, or Police Scotland on 101. Then find the project's escrow number in Dubai REST and ask the developer in writing to confirm where your money is.
Can UK investors recover a wrong-account off-plan payment?
UK investors can try to recover a wrong-account off-plan payment, but the route is uncertain. A SWIFT recall needs the recipient's acceptance and can take weeks. The UK APP reimbursement scheme excludes international payments. In Dubai, options include a written demand, DLD amicable settlement, the Dubai Courts or arbitration.
Is it illegal for a Dubai developer to take money outside escrow?
Dubai Law No. 8 of 2007 requires off-plan buyer payments to go into the project escrow account, but its English text has no stand-alone offence of receiving money outside escrow. Such conduct would be assessed under Article 16(4), which carries a fine of at least AED 100,000 and possible jail, or under other laws.
Why does Dubai escrow matter if the developer still has my money?
Dubai escrow matters because Article 9(1) of Law No. 8 of 2007 says escrow deposits serve only that project and cannot be seized by the developer's creditors. Money in a developer's general account has no such ring-fence. Escrow does not guarantee completion, but it limits how buyer money can be used.
Can I see whether my money reached the Dubai escrow account?
Yes. Article 12 of Dubai Law No. 8 of 2007 lets depositors or their representatives see their own accounting records in the escrow account and ask for copies. Request a copy after the developer says it has credited your payment, and keep it with your SWIFT confirmation.

Sources

  1. Law No. 8 of 2007 Concerning Escrow Accounts for Real Estate Development in Dubai (Dubai Legislation Portal)
  2. Dubai developers fined for off-plan sales violations (AGBI)
  3. Dubai REST (Dubai Land Department)
  4. APP fraud reimbursement protections (Payment Systems Regulator)
  5. Amend, trace and recall payments (Wise partner docs)
  6. Report Fraud (City of London Police)
HomeProof Research TeamFacts from Dubai law and official registries. HomeProof sells no property and takes no commission. About HomeProof

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.

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