Anti-Corruption in the GCC – Where is Compliance Headed?

Dubai-based Gulf Business published an short interview with Imelda Dunlop of the Pearl Initiative and Michael Adlem of Ernst & Young in the UAE regarding the spread of Anti-Corruption measures in the Persian Gulf region.  For me, the fact that such a topic was getting press and the content of the interview itself presented a significant milestone of sorts.  Working on sanctions compliance and fielding calls and clients alike in that part of the world, it’s very necessary to keep a finger on the region’s pulse when it comes to matters regarding trade and anti-corruption.  As such, I see that the arguments made forth by the two interviewees made sense.  Surely, the importance of compliance is rising.

It is unclear if strict local laws will be adopted.  Until then the de facto standards for trade compliance may likely be guided by US and UK benchmarks. With respect to US practices, the need for robust compliance programs on sanctions, export controls, anti-money laundering, and foreign corrupt practices is increasingly recognized.  Gulf operations of US companies often do not work in a vacuum, and with the imposition of secondary sanctions and wide-ranging grounds for jurisdiction of US law, the issue is becoming more tangible.

For American companies, the significance is quite clear – even many companies that have little business in the Gulf may use that region as a transit point for Africa, other points in MENA and South Asia. For local companies, as the Gulf Business interview hints, going global is increasingly on the minds of some. As such, compliance programs featuring preemptive measures (such as screening and reporting procedures) will be increasingly commonplace.

In the realm of sanctions, the impact is very much evident. On my most recent visit to the UAE earlier this year, my general impression was that the topic was much more salient than it was when I first started going to the region years ago.

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