"As foreign investment continues to
flow into Saudi Arabia, the risks of
corruption will increase. It is important
for businesses to have clear anticorruption
policies and procedures
in place so they are well equipped to
deal with challenges that may arise."
Tim Taylor QC
1. What is bribery?
Bribery in Saudi Arabia is a criminal offence
which can be committed by public officials or
private individuals according to the
Combating Bribery Law (the “CBL”).
The CBL penalizes the offering of any promise
or gift to a public official to perform or cease
to perform or neglect any of the public
official’s duties (of his function or claimed to
fall within his function), even where the act is
lawful, or to use the public official’s powers to
obtain from any public authority an order,
decision, commitment, authorization, supply
contract, job, employment, service or any
other kind of privilege, or to use the public
official’s powers to follow up on a transaction
in any governmental department. The
prohibition applies regardless of the intention
of the public official not to perform the act.
However, the CBL makes no distinction
between foreign and domestic public officials
and the Saudi government criminalises the
bribery of foreign public officials by Saudi
For foreign companies, Saudi Arabian courts
generally do not accept jurisdiction over a
foreign company if the elements of the bribery
take place entirely outside Saudi Arabia.
Foreign companies doing business in Saudi
Arabia, with or without a formal legal
presence in the country, are also subject to
the CBL with respect to their acts within
2. What are the
The briber or any middleman will be exempt
from prosecution under the CBL if they
voluntarily inform the relevant authorities
with respect to a crime before the crime is
3. What are the sanctions?
Sanctions for individual violators (including
public officials and principals of companies)
vary depending on the case and may include:
- up to 10 years imprisonment;
- fines of up to SAR1 million.
More from the Anti-Bribery and Corruption Guide:
Australia, Belgium, China, France, Germany, Hong Kong, Italy, Singapore, Spain, United Arab Emirates and United Kingdom.