In Korek Telecom Co LLC v Iraq Telecom Ltd (DIFCA 16/2024, 16 June 2025), the DIFC Court of Appeal has recognised the existence of the Foreign Act of State doctrine in DIFC law, but found on the facts that it did not apply so as to justify the setting aside of an ICC arbitration award. The Court also held that new Article 8A of the amended Applications Law (which came into effect on 21 November 2024) does not apply retrospectively. Zoe O'Sullivan KC acted for Korek (instructed by Boies Schiller).