In recent years, a number of international surveys and reports have benchmarked countries on the basis of their perceived levels of corruption. The UAE’s position, 23rd lowest of 168 countries, suggests that combating bribery and corruption are key areas on which organisations should focus.

Globally, increased perceived levels of bribery and corruption, coupled with emboldened prosecuting agencies using established (e.g., the US’s Foreign and Corrupt Practices Act 1977) and newer (the UK’s Bribery Act 2010) legislation have raised the importance of being properly prepared. In the UAE, enforcement of its established anti-corruption laws has received a boost with the Abu Dhabi Executive Council announcing the establishment of a new Anti-Corruption Unit in May 2015.

The investigation process

It is not possible to map out every individual component of an investigation as each will have its own features depending on the nature, scope and jurisdictional spread of the alleged behaviour. However, it is possible to identify the key phases for any investigation and to highlight some of the important issues to bear in mind.


Notification of the bribery offence having been committed by an organisation in the UAE may take a number of forms including contact from the Abu Dhabi Accountability Authority (ADAA) and/or the Ministry of Justice (MOJ), or from an internal process, e.g., internal whistleblowing, internal audit work or routine accounting checks.

Oct-Dec 2016 Issue

Winston & Strawn