Journal of Legal, Ethical and Regulatory Issues (Print ISSN: 1544-0036; Online ISSN: 1544-0044)

Research Article: 2020 Vol: 23 Issue: 6

Twofour54 Media Free Zone: Promoting Media Industry in a Censored Country

Khoa Tran, New York University Abu Dhabi

Anh Tuyet Nguyen, Nguyen Chi Thanh Gifted High School


According to twofour54's official website, acknowledging the spirit of H.H Sheikh Zayed, Sheikh Mohamed bin Zayed Al Nahyan initiated Abu Dhabi's 2030 Vision with the hope to build a sustainable and diversified economy with a strong recognition of international openness. To achieve this objective, he recognized that media is not only a source of mere entertainment and information; it also plays a vital role in national development and national branding in an international context. Media reflects citizens' collective voice and brings UAE culture and presence to join hands with the modern world's international growth. One of the 2030 subvisions is to make Abu Dhabi a globally recognized hub for the media industry. However, the United Arab Emirates and Abu Dhabi face a conflict in interest between liberal media promotion and national censorship, which protects the UAE's political-cultural stability. To solve this conflict, the Abu Dhabi authority established twofour54 in Abu Dhabi. This research would use film production as a case study for twofour54 regarding solving the media-censorship conflicts.


Censorship, Economic Free Zone, Film production, Islamic, Media, United Arab Emirates.


The current development of the media industry in the United Arab Emirates (UAE) and the establishment of the media free zone twofour54 were foreseen by the UAE’s national father H.H Sheikh Zayed’s vision.

"I had many dreams. I dreamt of our land keeping pace with the growth of the modern world. Sheikh Zayed bin Sultan Al Nahyan, father of the United Arab Emirates”

Sheikh Zayed hopes for the UAE to keep up with the global development and become a part or even a leader of this movement. According to twofour54’s official website’s The Abu Dhabi Economic Vision 2030, acknowledging the spirit of H.H Sheikh Zayed, Sheikh Mohamed bin Zayed Al Nahyan initiated the Abu Dhabi’s 2030 Vision with the hope to build a sustainable and diversified economy with a strong recognition on international openness. To achieve this objective, he recognized that media is not only a source of mere entertainment and informative; it also plays a key role in the national development and national branding in an international context. Media reflects the collective voice of citizens and brings UAE culture and presence to join hands with the international growth of the modern world. Moreover, the media industry also shows fast-growing economic opportunities for the MENA region. One of the 2030 subvision is to make Abu Dhabi become a globally recognized hub for the media industry (120). However, the United Arab Emirates and Abu Dhabi face the conflict in interest between liberal media promotion and national censorship which protect the UAE’s political-cultural stability. To solve this conflict, the Abu Dhabi authority established twofour54 in Abu Dhabi. According to its official website, the twofour54 free zone is a special economic zone (SEZ) located in Abu Dhabi, the capital of the United Arab Emirates. Its name honors the geographical co-ordinates of Abu Dhabi (24° North, 54° East), and this SEZ serves as a regional media hub for film and creative productions in the UAE. This area aims to provide economic incentives, rebrand Abu Dhabi’s media industry image and redefine the censorship to grow UAE’s media industry without the need to reduce the level of censorship. The conflict between media promotion and censorship is not limited to the twofour54 area and the UAE. Understanding this conflict is fundamental to promoting new thought and comparative evaluation of the effectiveness of special economic zones worldwide and how a country can balance governmental interests with freedom of public expression. This essay argues that despite the current restriction and censorship, the establishment of twofour54 is undeniably a stepping stone toward international openness and promotes the freedom of press and expression within the UAE because of its initiative in economic incentives, re-branding Abu Dhabi and redefining the censorship within Abu Dhabi.

Literature Review

Special Economic Zone (SEZ)

Hsu & Chu (2017) defined a special economic zone (SEZ) as a specially designed and established zone to boost the national economy. In the establishment of SEZ, specific regions are regulated by distinct regimes of governing, which are different from that of the rest of the country. The appearance of SEZs is ubiquitous, and its number is rising significantly. In its World Investment Report, (United Nations Conference on Trade and Development, 2019), the United Nations Conference on Trade and Development analyzed that there were 5400 SEZs across 147 countries, compared to just 3500 ones across 130 economies in 2006. Many scholarly articles considered SEZs a valuable driving force behind the economic and political improvement. This is because the SEZ consists of collectively managed globalization (Hsu & Chu, 2017) and an international arena for policymakers to evaluate institutional arrangements' responsiveness and adaptiveness (Doucette & Lee, 2015). Additionally, these zones are an investment to attract foreign capital, stimulate trade and promote export-oriented growth (Ong, 2004); they are also displaying complex hybridity yet maintaining the restrictive and protective regulations in other areas of the country(Phelps & Wu, 2009).

Hartwell (2017) suggested that while the extent of SEZs' influence might vary, they incentivize national institutions' improvement when serving as a 'small country in a large country.' For example, in the case of Poland, its government's blend of EU's regional state aid policy and financial and legal benefits of SEZs indicated that SEZs scheme considerably assists in establishing an investor-friendly environment (Kaneko, 2017). Additionally, Countries integrating SEZs successfully, such as South Korea, Taiwan, and China, is likely to witness economic multiplier effects; helping surrounding regions increase their employment rate and technology transfer (Hsu & Chu, 2017). This is also supported by the research investigating SEZs' supporting role in the Western Balkans, which revealed that SEZs network appeals to more foreign direct investment, generates employment, and fosters export competitiveness. However, this research indicates that the linkage between businesses in SEZ and local ones is limited, and little is the technology transfer to local economies (Bartlett et al., 2019). Despite some evidence about SEZs' effectiveness in many nations, it is also shown that SEZs play an insignificant part in the development of countries, for example, Russia (Mamleeva et al., 2020). Therefore, not all economies get benefits from SEZs.

According to previous research on SEZs impacts on the economy, researchers show the potential to promote economic growth and liberalization but still keep upkeeps the national policies; however, these pieces of research are on a case by case basis. The literature gap and controversy on promoting freedom in SEZ motivates the research papers to investigate in twofour54 media zone of the UAE.

Political and Media Challenges in Islamic World

The current state of Islamic media has been assessed in the previous research. In 2015, the Middle East's largest cinema market, UAE, witnessed a modest number of films in the Arabic language, which accounted for a mere 8% of all titles screened and 3% of box office revenues (Dennis et al., 2013). Consequently, this small proportion of mainstream film, television, music, and digital content produced in or about the Arab Gulf has challenged the cultural change process, fueled by the popular culture reflected in entertainment media (Shafik, 2016). Besides, the perception of Islamic Media is binary in the western world's views and scholars. European and North American observers usually assume that Middle Eastern governmental bodies forcefully hinder residents from getting access to a wide range of artistic expression and abridge speech against entertainment audiences' favor. However, like many American Millennials leaning towards censoring statements affecting minorities negatively, laypersons in the Arab world support government abridgment of some offensive speech types. Conversely, activities on blogs and social media where people can express their outcry over their autocratic regime have strengthened recent calls for reform (Martin et al., 2016).

Although limited in number, there is previous research on censorship support in the Middle East. Research in 1994 found out that more media users tend to support violent materials' censorship than abridgment of sexual material (Fisher et al., 1994). Citizens in Qatar and United Arab Emirates supported the censorship because of its cultural preservation characteristics while those in Saudi Arabia and United Arab Emirates supported for their desire to have more entertainment products embodying cultures and history. However, three of those countries all supported more severe censorship due to the belief in Hollywood films' adverse effects on morality (Martin et al., 2016). However, one research also points out that the gender-based bias of the government-own press's censorship aggravates gender inequality in the Middle East. Thanks to the open social media, which assisted women in self-expressing, the research expressed that gender inequality was marginalized (Odine, 2013). Suggesting by previous scholars, it is necessary to acknowledge that there is no research addressing the progress to improve media freedom in the United Arab Emirates; hence, this paper wants to fill this literature gap.

Research Methodology

This commentary research employs the case study approach, which allows a multifaceted insight into this complex phenomenon in its real-life context. The single case study digs into the issues in depth rather than breadth, endowing the paper with thickness and detail (Crowe et al., 2011). Researchers employ this method to analyze the impacts of SEZ on the economy and social development. Previous research in Poland and Russia highlighted the approach's validity (Kaneko, 2017; Mamleeva et al., 2020). Since SEZs? application and their policies are unique to national contexts, this approach is a suitable method to capture twofour54's unique nature and generate knowledge for theoretical development in promoting media freedom in censored countries. This case study will concentrate on the twofour54 Media Zone and the media regulation with the United Arab Emirates. The research follows an interpretative approach to analyze the impacts of twofour54 and its impacts on the UAE's media development and censorship from different perspectives. To prevent the criticism of "difficult to explain unintended consequences and for neglecting surrounding historical contexts," we will explore the social and historical context of UAE (Crowe et al., 2011).

The authors adopt the narrative and document research methods, supported by an addictive approach, to thoroughly interpret the case study of twofour54 Abu Dhabi. Our main sources come from research papers, primary sources of law, government publications, and commentaries from media and human rights experts, reflecting the nature of UAE's media and censorship. After going through United Arab Emirates regulations on the media industry, this case study analysis with twofour54 discusses the special economic zone, economic incentives, the contribution of twofour54 to rebranding Abu Dhabi's media industry, and redefining the views on censorship via media zone. Finally, the research will provide suggestions for future research and investigations on the impacts of SEZ zones on promoting freedom of media. In general, the research contributes to theoretical analysis in media freedom, cultural protection, and media censorship, specifically in the MENA region and the UAE.

United Arab Emirates Regulations on the Media Industry

To understand the significance of twofour54, it is crucial to understand the definition of the media industry and social-political censorship in the context of twofour54 and Abu Dhabi. Firstly on twofour54's official website, the media industry encompasses various sectors such as advertising, event planning, and gaming, entertainment, and device manufacturers. They diversify in services and sectors to make twofour54 a media ecosystem. This ecosystem can sustainably encourage media industry development. However, because this zone sets film & TV services in priority and is the most relevant to media censorship, this analysis would use film production as a case study for twofour54 regarding solving the media-censorship conflicts. Secondly, since the UAE's society and government are strongly linked with Islamic culture; hence, censorship is to protect the political interests and the cultural value of the UAE.

While different perspectives about censorship will be discussed in the latter part of this research, it is also necessary to know how the UAE's current level of censorship can limit their media industry development. Telecommunications Regulatory Authority's (2019) internet guideline (TRA) mentions the prohibited content nationally, including: “"Pornography and nudity content, promoting destructive principles such as homosexuality, leaving Islam, contrary to the teachings of Islam."”. In other words, film productions must not go against Islamic values, and many Western film features such as nudity and LGBTs are also prohibited. Since there are difficulties for nonMuslin film producers to navigate the Islamic values, they would typically choose other countries with a lower level of censorship and better media relationship with the Western world like Morocco and Egypt to make the film in the MENA region (Murphy, 2011; Martin et al., 2016).

Twofour54 and Special Economic Zone

To keep the censorship level for political stability and traditional culture, the Abu Dhabi government establishes twofour54 as an SEZ to become more competitive and attractive regionally. This region is an economic-legislative tool for Abu Dhabi's government to promote the media industry while keeping their current censorship level. According to twofour54's official website, this media free zone has these four pro-media, pro-business and legislative features such as:

“"0% import tariffs", "licensing and registration fees by the Media Zone Authority-Abu Dhabi have been waived for the first two years," "strong IP protection framework," "proximity to Downtown Abu Dhabi, International Airports, Port, Yas Island; just 50 minutes away from Dubai."”.

These are examples of desirable economic and legislative policies that make twofour54 an attractive place for investors and film producers. These features promise film producers high revenue and profits, first-class treatment, and global networking opportunities; thus, this zone aims to rebrand Abu Dhabi as a progressive media industry despite censorship. The government also introduced The Media Zone-Abu Dhabi Content Code (2016) along with twofour54 to set the production-content guideline within this free zone. This code plays a vital role in redefining media censorship within Abu Dhabi and the UAE. These economic, legislative, and branding features are the stepping stone for the government to show the UAE's progressive media industry's development and dim the high censorship reality.

Economic Incentives at Twofour54

These features highlight the first role of twofour54: attracting film producers with economic incentives. The film producers might participate in twofour54 despite the limitation in freedom of expression because this media free zone can generate large profits for the businesses. The tangible evidence is many Hollywood films, such as: ?Star Wars: The Force Awakens, Furious 7, and War Machine? have been produced in UAE due to its financial rebate and tax policy:

“ "Fast and Furious 7 and Star Wars, Episode VII have both come to the UAE to film, lured by 30% rebates and first-class treatment from Abu Dhabi government's media production entity, twoFour54 (Yunis, 2014)".”.

In other words, Yunis suggests that financial incentives are the key elements to choose Abu Dhabi as the filming place. The neoclassical economics theory can explain the winning of financial incentives over the restriction of media freedom: "firm exists and makes decisions to maximize profits." Neoclassical economists believe companies value profit as a top priority factor, and it is willing to accept any opportunities to maximize its profits. Film producers usually consider the restriction in freedom of expression as only a factor that can prevent their profit generation. In censored countries, the production cost may rise because the producers must hire legal experts to ensure that the contents have adhered to UAE's law. Films without violent elements may not attract the European and North American market (Cerridwen & Simonton, 2009); thus, media censorship makes film producers earn less revenue. Hence, when the financial benefits in twofour54 override the income loss due to the restriction of expression, film producers might not hesitate to produce a film in this zone. This suggests that economic factors in twofour54 can play a key role in mediating economic-media promotion and political-cultural interest conflicts.

However, Zeng argues that providing these financial benefits are costly to the government; hence, it might not be a sustainable solution to solve economic-media and politicalcultural interests conflict. Firstly, "100% exemption from corporate taxes and personal income taxes" and "30% cash rebate on production spend" means the government has to increase its national expenditure. These financial benefits are the burden that can create a loss in UAE national income. If there is an economic crisis, and the government cannot ensure the subsidy, the whole media free zone could collapse (Zeng, 2019). In other words, the media free zone is not a self-sustaining market. However, this might not be the case for Abu Dhabi's twofour54. Paul Baker, executive director of twofour54, said:

“"In a study commissioned by ADFC earlier this year, PricewaterhouseCoopers (PwC) estimates that for every Dh1 invested in the production rebate program, Dh4.5 of GDP will be generated within Abu Dhabi" and "total economic impact of the rebate program in 2014 to be Dh180 million".".

In other words, statistical research shows that rebate programs are not a financial burden. It is a profitable economic scheme with 400% of profits and brought over 46 million USD for Abu Dhabi in 2014. Beyond that, the director also mentions,

“ "Star Wars has several hundred casts and crew who stayed in hotels and dined at restaurants in the emirate, which in turn contributed to the local tourism market and boosted hotel occupancy (Tamimi, 2018)"”.

This means that film production's activities also create jobs and revenues for other businesses within the UAE. This evidence shows that twofour54's economic incentives are sustainable methods to promote media within a censored country like the UAE and contribute to the bigger UAE's economic development.

Twofour54: Rebranding Abu Dhabi’s Media Industry

After successfully attracting the local and international film producers, the second role of twofour54 is to rebrand Abu Dhabi as a progressive and welcoming media industry. This rebranding is needed to dim the implication of high censorship levels because the censorship connotation could prevent investors and film producers from considering Abu Dhabi as a production place. In the twofour54 press release, several branding techniques can be spotted: emphasis on awards, international connections, and Arabic culture promotion. For example, twofour54 announced various prestige awards, such as:

“ "Twofour54 enhances its post-production facilities through Dolby Vision certification" or "twofour54 Abu Dhabi named 'Broadcast Services Provider of the Year' for the second time in a row".".

By branding as a leader and an international media region, twofour54 increases its credibility and Abu Dhabi's international image. Good branding gets recognition from international film producers and motivates Emirati citizens to work in the Arabic media industry since it creates national pride. This rebranding benefit allows Abu Dhabi's to promote media with both inner-force and outer-force. Moreover, by hosting international news channels, such as CNN and Fox, Abu Dhabi allows its citizens to access not only international information and news worldwide but also the more objective views from the Non-Arab context. This shows that the Abu Dhabi government has opened to a more considerable extent of freedom of expression within the emirate. Twofour54 might not solve the censorship problems, but it shows the progress in media production and international openness that Abu Dhabi's government aims at.

Critics also argue that access to international media is not equivalent to uncensoring citizens toward the government's sensitive topics. Rebranding is not essential if the core issue, the censorship, is not changing. In twofour54's Media Zone - Abu Dhabi Content Code's section of children, religion, and crime, many typical Western media features are still prohibited in twofour54. The code prohibits films that have’ "portrayal of sexual activity," "offensive language, violence, nudity, sex, sexual violence, humiliation," "disparages the views and beliefs of a religion and in particular Islam"?“(6-11). According to Nicholas McGeehan (2010) from Human Rights Watch, these content codes are merely a tool to prevent filmmakers from exposing the UAE's violent side (2010). Moreover, as these typical Western media features are prohibited, twofour54 closes the doors for many potential filmmakers from the West to invest in UAE, especially for violent and gender-related genres. For example, the authority refused to produce the film Sex and the City 2 because “the theme of the film does not fit with our cultural values". The word “sex” is the problem. The director of this film said in his interview with The Los Angeles Times:

"The idea of sex and these liberated women being filmed there was a little too progressive for their…where they are right now."

The director believes the political aspects and non-progressive idea of "sex" limit film production within the UAE. The refusal to produce Sex and the City 2 will de-motivate other film producers from creating movies of the same genre in the future. This is an example of how censorship is still preventing film producers from creating content even in a media freezone like twofour54 freely.

Twofour54: Redefining the Views on Censorship Via Media Zone

In response to the criticism regarding the refusal to produce Sex and the City 2, another viewpoint suggests that the censorships protect Islamic culture. For example, mentioned by twofour54's press release, the government refuses to produce Sex and the City 2 not only because of the word "sex"; the film also portrays the Emirati women from an orientalist perspective. p>

“Sex and the City 2 feature a fully covered Arab woman being examined by the American stars like a zoo animal as she navigates eating French fries with her niqab”.

This scene shows the ignorance and disrespect of the directors toward the Emirati culture. As Abu Dhabi's government has a responsibility to promote and protect its nation's cultural heritage, the ban of Sex and the City 2 due to cultural inappropriateness is valid. However, despite the twofour54 media zone, not hosting the film, the government still allows the film set to be in Abu Dhabi. This decision questions the branding strategies of the UAE. Nicholas McGeehan also mentions:

“The country's rulers believe flashy public relations will always prevail over wishy-washy notions of equality, justice, and fundamental rights, and that it is possible to go on violating those rights in the most obscene and flagrant manner, as long as the brand remains untarnished.”

He criticizes the superficial values of branding without changing reality in that twofour54 cannot truly promote media if the government does not reduce the level of censorship and respect media freedom (McGeehan, 2010).

This comes to the third role of twofour54: redefining the views on censorship Via Media Zone using the The Media Zone–Abu Dhabi Content Code. The Media Zone–Abu Dhabi Content Code explains valid reasons for all the prohibition contents. For example, the nudity and sexual activities are banned because “the dignity, welfare, and safety of children are paramount and all children have a right to be safeguarded from harm.” In other words, the censorship in nudity is justified as Abu Dhabi wants to include all citizens into media, including children. Similar to the explanation for prohibiting nudity and sexual activities in films because of children’s wellness, other prohibitions are also explained by the welfare of citizens and national values of the UAE. (6-12) In other words, the prohibitions are not imposed to limit the creativity of producers, but to help the producers to avoid offending religious beliefs or national culture of audiences. Hence, the refusal of twofour54 to produce Sex and the City 2 might be a progressive development of UAE’s media industry because it protects UAE’s cultural values.

Moreover, the Media Zone-Abu Dhabi Content Code also suggests the larger extent of freedom of content compared to the nation’s Telecommunications Regulatory Authority:

“Rule 2.1: Content that has the potential to cause offense must be justified by the context (please note the definition of context on page 4). Such content includes, but is not limited to: offensive language, violence, nudity, sex, sexual violence, humiliation, and distress, violation of human dignity, treatment or language that is likely to promote prejudice.”

Unlike the nation’s regulation that banned these contents, twofour54 media free zone allows the film producers to justify the context of their films before making the decision. By changing from banning contents to allowing justified contents in law, twofour54 has made a practical move to reduce the censorship within Abu Dhabi’s region for the media industry. For example Furious 7, Movie Guide’s critics rate the film’s language and violence as “heavy”, nudity as “moderate” and sex as “light”. These contents are against the national Telecommunications Regulatory Authority. However, the film can be produced in Abu Dhabi’s twofour54 zone because the film producers had justified the content. For example, “women in bikinis and other skimpy clothing and female cleavage and upper male nudity” are justified in the context of a beach, where it is acceptable to wear bikinis in Abu Dhabi. Therefore, despite these prohibited contents in the TRA’s rules still not being freely produced in twofour54, twofour54’s legislation has improved the freedom of contents in media.


Twofour54 is a battleground between censorship for political-cultural stability and media promotion within the UAE and Abu Dhabi. After 11 years, twofour54 has promoted the media’s industry in Abu Dhabi with concrete evidence on international openness and progress toward Abu Dhabi’s 2030 vision. Despite showing some limitations on freedom of expression, twofour54’s economic incentives, branding strategies and legislations have attracted local and international investors and filmmakers to join hand into the progress of promoting Abu Dhabi to become a globally recognized media hub. The essay also shows that the conflicts between media promotion and political-social’s interests can be mitigated by economic factors, pro-business factors, or redefining censorship. Finally, prohibitions in media are not necessarily limitations of freedom of expression, but they could also be a protection for media audience and the cultural interests. Beyond the scope of UAE, the implementation of twofour54 may not be possible for developing nations due to its requirement of government spending according to Zeng; however, an SEZ can be used to promote media for developed nations (Zeng, 2019). There are always drawbacks to keep the high level of censorship; however, if a country has effective pro-business legislation, the media industry could still grow progressively.

Limitation and Suggestions for Future Research

There are some limitations in our research that should be noted. First, the use of the case study approach needs external validity. To address this limitation, future research could adopt quantitative methods or generate interviews and questionnaires with stakeholders to thoroughly interpret the issue. Second, the case study analysis of twofour54 is still limited to the media industry. Therefore, future papers could study other creativity-related fields, such as advertising, artistic activities. Finally, the lack of comparison with other media zones in the Middle East in particular and across the globe in general also limits the deduction. Accordingly, it is crucial for future studies to employ a comparative approach with a broach range of constructs.

We hope future research to develop quantitative solutions to promote freedom of speech and cultural appreciation across the globe and within the UAE. This will be an essential contribution to promoting human rights in the UAE and portrays UAE's and Islamic cinema's branding progressively and positively in global mainstream media.


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