Anti-corruption regulation—United Arab Emirates—Q&A guide

The following Corporate Crime practice note provides comprehensive and up to date legal information covering:

  • Anti-corruption regulation—United Arab Emirates—Q&A guide
  • 1. To which international anti-corruption conventions is your country a signatory?
  • 2. Identify and describe your national laws and regulations prohibiting bribery of foreign public officials (foreign bribery laws) and domestic public officials (domestic bribery laws).
  • 3. Can a successor entity be held liable for violations of foreign and domestic bribery laws by the target entity that occurred prior to the merger or acquisition?
  • 4. Is there civil and criminal enforcement of your country’s foreign and domestic bribery laws?
  • 5. Can enforcement matters involving foreign or domestic bribery be resolved through plea agreements, settlement agreements, prosecutorial discretion or similar means without a trial? Is there a mechanism for companies to disclose violations of domestic and foreign bribery laws in exchange for lesser penalties?
  • 6. Describe the elements of the law prohibiting bribery of a foreign public official.
  • 7. How does your law define a foreign public official, and does that definition include employees of state-owned or state-controlled companies?
  • 8. To what extent do your anti-bribery laws restrict providing foreign officials with gifts, travel expenses, meals or entertainment?
  • 9. Do the laws and regulations permit facilitating or ‘grease’ payments to foreign officials?
  • More...

Anti-corruption regulation—United Arab Emirates—Q&A guide

This Practice Note contains a jurisdiction-specific Q&A guide to anti-corruption regulation in United Arab Emirates published as part of the Lexology Getting the Deal Through series by Law Business Research (published: October 2020).

Authors: Afridi & Angell—Charles S Laubach ; Alex Vromans

1. To which international anti-corruption conventions is your country a signatory?

The United Arab Emirates (UAE) ratified the United Nations Convention against Corruption (the UNCAC) pursuant to Federal Decree No. 8 of 2006. The Arab Convention to Fight Corruption (the Arab Convention) was signed on 21 December 2010 by 21 Arab countries, including the UAE.

2. Identify and describe your national laws and regulations prohibiting bribery of foreign public officials (foreign bribery laws) and domestic public officials (domestic bribery laws).

Domestic bribery laws

Bribery is punishable in the UAE according to articles 234 to 239 of the UAE Penal Code, Federal Law No. 3 of 1987 (the Federal Penal Code), which applies to the UAE as a whole. The Emirate of Dubai also has its own penal code, the Penal Code 1970 (Dubai Penal Code).

In addition to the above, two further laws are directly related to bribery. These are Federal Decree-Law No. 11 of 2008 (also known as the Federal Human Resources Law) and Dubai Law No. 37 of 2009 on the Procedures for the Recovery of Illegally Obtained Public and Private Funds (Financial

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