From the journal

DIFC Digital Economy Court Dismisses 300-Bitcoin Custody Claim Against Tabarak, 2026

The DIFC Digital Economy Court has handed down judgment in Gate MENA DMCC and Huobi MENA FZE v Tabarak Investment Capital Limited and Christian Thurner, dismissing the claimants' case in full. The retrial, heard over five days in February 2026, addressed contract formation under DIFC and common law in the context of a 300-Bitcoin OTC transaction disputed since 2020.

3 min read

The DIFC Digital Economy Court handed down judgment in Gate MENA DMCC (formerly Huobi OTC DMCC) and Huobi MENA FZE v Tabarak Investment Capital Limited and Christian Thurner. The retrial ran for five days from 2 to 6 February 2026, addressing legal and factual issues concerning contract formation under DIFC and common law in an OTC Bitcoin transaction. The court dismissed the claimants' case in full.

Justice Black held that a new contract arose during the execution of the Bitcoin transfer, notwithstanding the failure of the parties' original agreement. The court found that the parties intended to create legal relations, that Tabarak acted for reward, and that the transaction proceeded on the basis of a newly agreed arrangement arising from conduct and performance. Because the earlier Court of Appeal finding that Tabarak acted reasonably was binding on the retrial court, no breach was established and the claim failed.

OTC digital asset brokers, custodians, and escrow service providers operating in the DIFC, or transacting under DIFC law, now have clear authority for the principle that binding obligations can arise from conduct during digital asset settlement, even where the parties' original agreement has fallen away. Counterparties structuring OTC crypto trades should document each step of settlement explicitly, particularly where custody is delegated mid-transaction or where wallet addresses change during execution. Risk allocation clauses in OTC agreements governed by DIFC law should account for the court's willingness to imply new contracts from transactional conduct.

The judgment does not establish what standard of care applies to crypto custodians acting for reward where the parties have agreed no written custody terms. Open questions remain about how DIFC courts will treat losses from mid-settlement instructions, particularly where a custodian follows a buyer's self-custody instruction without challenge and no independent verification of wallet authenticity was conducted.

Licentium advises digital asset businesses on dispute risk, regulatory compliance, and jurisdictional structuring in the UAE and MENA region, including the DIFC and ADGM special economic zones. We maintain a partner network of DIFC-registered lawyers and dispute resolution specialists for contentious matters in the Gulf and wider Middle East. To discuss how this judgment affects your OTC trading or custody operations, contact us. Work we undertake includes DIFC regulatory structuring, OTC agreement and custody review, virtual asset dispute risk analysis, and cross-border enforcement strategy.

Source: Mishcon de Reya, Gate MENA DMCC and Huobi MENA FZE v Tabarak Investment Capital Limited, DIFC Digital Economy Court retrial judgment analysis, 2026

Crypto Regulatory

More from the journal

See all
Illia Prokopiev

From Cloud Concentration to AI Dependence: The UK’s Critical Third Parties Regime

The United Kingdom now directly oversees designated technology suppliers whose service failures could threaten financial stability. The question is whether the first cloud designations show a legal expansion toward AI-model providers, and what the present regime requires. This analysis assumes the quoted statement concerns the UK financial-services Critical Third Parties regime and assesses the law through 14 July 2026.

Alberta Regulated iGaming Market Launched on 13 July 2026 with 22 Operators

Alberta's regulated private iGaming market launched on 13 July 2026, making Alberta the second Canadian province to permit private online gambling operators after Ontario. The Alberta Gaming, Liquor and Cannabis Commission serves as market regulator and the Alberta iGaming Corporation oversees commercial operations and operator contracts. Twenty-two operator sites went live on day one, including FanDuel, DraftKings, BetMGM, and BetRivers. Operators must fully launch or exit the Alberta market by 13 October 2026.

European Commission Presents Cybersecurity and AI Action Plan on 7 July 2026

On 7 July 2026, the European Commission presented an Action Plan on Cybersecurity and Artificial Intelligence. The plan directs the Commission and ENISA to evaluate advanced AI models before they reach the EU market, establish a secure testing platform for critical-sector organisations, and launch an EU Grand Challenge on AI-powered cybersecurity solutions. It operates alongside the AI Act, NIS2 Directive, DORA, Cyber Resilience Act, and Cyber Solidarity Act, and introduces no new directly binding obligations.