As a country, the United Arab Emirates is probably less well-known than Abu Dhabi and Dubai, two of the seven emirates that make up the nation. Abu Dhabi, the nation's capital, has developed a significant global profile primarily due to its oil wealth. Dubai, the country's major commercial centre, has developed a global reputation due in part to the speed of its economic development over the last few years, but also due to its role as a regional logistics hub, as a luxury holiday destination, and as home to Emirates Airline.
In the UAE, sales promotions - including sales, as well as competitions and prize draws (including prize campaigns, sweepstakes, raffles, and instant prizes) - are regulated on an emirate-by-emirate level in each of the seven emirates that make up the UAE. In Dubai and Abu Dhabi, the respective Departments of Economic Development ("DED") require entities planning sales promotions to first obtain a permit. If a promotion were to specifically target any of the other emirates in the UAE, then it would be appropriate to consider seeking permits in such emirates.
The process for obtaining a sales promotion permit from the DED is straight-forward, and can usually be completed within a week or so. Information on the proposed promotion, such as its general nature of the promotion, the nature, quantity and value of any prizes, and the period over which the promotion will be run, need to be submitted to the DED, along with a copy of the organiser's trade licence and premises lease, an application form for the permit, and the official fee. Official fees are relatively modest, and can vary depending on aspects such as the duration of the promotion, the value of any prizes and the extent of any advertising.
Prizes that are products such as tobacco, alcoholic beverages or pharmaceuticals, are not permitted. Cash prizes are generally not permitted, although they may be permissible in circumstances where cash is a key aspect of the organizer's core business (such as a money exchange). There are no prescribed requirements with regard to any 'skill' element. Raffle-type prize draws where participants simply purchase tickets are generally not permitted. For competitions involving prize draws, it is necessary to have an official from the DED in attendance at the prize draw to act as an official witness.
Running a sales promotion without a permit can attract a penalty. The penalty can vary depending on whether the sales promotion is one for which a permit, if sought, would have been issued. Generally, if the subject matter of the competition is not something that the DED would have approved, then higher penalties are likely to apply.
There is only a limited likelihood of the DED taking issue with an on-line promotion not specifically targeting participants in the UAE. If the DED did become concerned by the absence of a permit for such a promotion, then the most likely outcome would be for it to liaise with the local telecommunications regulator to have access to the offending site blocked.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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