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Creditor Fraud in Insolvency: Fictitious Debts and Secret Deals

Offences by creditors and others in an insolvency: false debts, secret agreements, buying votes and taking part without the right to.

Last updated 9 October 2026. Statutes checked against the official text.

Dr Fadil Ali Alzarooni
Speak to a lawyerDr Fadil Ali AlzarooniCriminal defence, AK Criminal Lawyers

What can a creditor be punished for?

Article 275 of the Federal Decree-Law No. 51 of 2023 (Financial Restructuring and Bankruptcy Law) punishes a creditor of a debtor against whom proceedings have been initiated, with imprisonment and/or a fine of up to AED 300,000, who increases their debt by fraud, obtains special benefits in exchange for voting in favour of the debtor, or secretly agrees with the debtor after cessation of payment to give themselves special benefits to the detriment of other creditors.

The court declares such secret agreements invalid and orders the creditor to return what was taken, even if an acquittal is given.

What about fictitious debts?

Article 276 punishes whoever fraudulently submits fictitious debts in their name or in the name of third parties with imprisonment and/or a fine of up to AED 500,000.

Article 278 punishes a creditor who deliberately overstates their debts, takes part in deliberations or voting while knowing they are prohibited, or makes a secret agreement for special benefits, with imprisonment of up to two years and/or a fine of up to AED 200,000.

Can someone who is not a creditor be liable?

Yes. Article 279 punishes someone who is not a creditor and gets involved in deliberations or voting knowing they are not, with imprisonment of up to one year and/or a fine of up to AED 200,000.

Article 280 punishes willfully refusing to execute a decision of the Bankruptcy Court to submit data, information or documents or give testimony, with imprisonment of up to one year and/or a fine of up to AED 200,000.

What do I need to protect myself as a creditor?

Accurate claims backed by documents, and no side agreements with the debtor. If a debtor offers a benefit for your vote or for preference, decline and tell your lawyer.

Keep all communications with the debtor and the trustee.

What should I do first?

  1. File accurate claims with documents

    Overstating is an offence.

  2. Do not accept side benefits

    They are void and punishable.

  3. Do not vote if you are not entitled

    Check with your lawyer.

  4. Keep all correspondence

    It shows good faith.

Call us on +971 50 653 1334 or message us on WhatsApp. We answer at any hour.

Frequently asked questions

Is overstating a debt a crime?

Yes. Article 278 provides up to two years and/or a fine of up to AED 200,000.

What about a secret deal for a better payment?

Article 275 and Article 278 punish it and the court declares it invalid.

Can a non-creditor be punished for voting?

Yes, under Article 279.

Does acquittal save a secret deal?

No. The court declares it invalid and orders return of the assets even if an acquittal is issued (Article 275(2)).

Related guides

Sources

Source: Federal Decree-Law No. 51 of 2023 (Financial Restructuring and Bankruptcy Law), official English text on the UAE Legislation portal, checked 9 October 2026. The portal lists the law as active, in force from 1 May 2024. The Arabic text prevails over translations.

This page is general information, not legal advice.

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