The UAE has a comprehensive legal framework against corruption, but it is scattered across various laws and codes of conduct (Baker McKenzie 2017). On the Federal level, the UAE Penal Code criminalizes corruption, embezzlement, abuse of office, passive and active bribery, bribery or attempted bribery of public employees, a term that covers everyone performing a job for the public service. The revised Penal Code of 2016 makes it illegal to bribe a foreign public official (Baker McKeznie 2017). Facilitation payments are considered a form of bribery (Baker McKenzie 2017). Whether a gift is considered appropriate depends on a number of factors, including its value, the intention behind the offer, the frequency with which gifts are offered, and the relevance of the gift (Baker McKenzie 2017). The mediator or middleman between the recipient and the person offering the bribe is also guilty of an offense (Ethic Alliance, 2016). In the private sector, however, only an individual who accepts a bribe, in exchange for acting in violation of the duties of their position is guilty of an offense (Baker McKenzie 2017). A public official found guilty of accepting a bribe is sentenced to five to ten years’ imprisonment, while a private person or a mediator trying to bribe faces a maximum of five-years’ imprisonment. Federal Law on the Criminalization of Money Laundering criminalizes money laundering. The Federal Human Resources Law provides specific provisions addressing gifts, bribes, and conflicts of interest among federal government employees. The Dubai Government Human Resources Management Law aims at curbing government corruption in Dubai, while Law No. 1 of 2006 contains anti-corruption provisions and civil service conduct regulations for the Emirate of Abu Dhabi. The UAE has ratified the United Nations Convention against Corruption (UNCAC).
In terms of corporate governance, two-thirds of board-level executives in Dubai have indicated in a survey that they believe their anti-bribery policies are failing, and only slightly more than a third say they understand their own company’s anti-bribery policies (Arabian Business, May 2016).