TPRM in the Middle East and Best Practices for Proactive Compliance

Organizations operating in the Middle East are facing a fundamentally different third‑party risk landscape than they were even five years ago, and the webinar’s central message is that compliance teams must move from checkbox due diligence to a continuous, risk‑based, tech‑enabled model that is deeply adapted to local realities.​

We explored these topics in our recent webinar, Navigating Third-Party Risk in the Middle East, and Best Practices for Proactive Compliance featuring Luay Asadi, Head of Group Ethics and Compliance at Careem and GAN Integrity’s Colin Campbell. You can watch the full webinar at any time, on demand.

The New Third‑Party Risk Landscape

The Middle East is an “incredibly diverse geography” of roughly 500 million people spread across more than 20 countries from Morocco to Pakistan, with very different legal systems, cultures, and risk profiles. Over the past decade, several forces have combined to reshape third‑party risk management (TPRM) in the region: the shock of COVID‑19, maritime and airspace disruptions, sanctions, and a fast‑evolving regulatory environment around privacy, ESG, and data governance.​

As a result, leading companies are moving beyond basic background checks and instead focusing on whether third parties share their standards on regulatory compliance, privacy, ESG, information security, and sanctions, and on understanding who actually owns those entities through ultimate beneficial owner (UBO) analysis. The shift is from transactional vetting to a broader focus on resilience and shared values.​

Why “One Middle East” Is the Wrong Mindset

One of the strongest warnings in the discussion was against treating the Middle East as a single, homogeneous market. Unlike the United States, with one overarching federal system, or the EU, with common regulations and directives, the region comprises many jurisdictions with distinct laws and enforcement cultures.​

The speakers stressed that assuming a one‑size‑fits‑all compliance framework will work across the region is “the biggest mistake multinationals can do.” Companies arriving with a sound framework from abroad but failing to calibrate it to local rules, customs, and languages risk serious gaps. Success in TPRM requires:​

• Recognizing the diversity of the 22+ countries in scope, often excluding additional markets like Turkey, Iran, and Pakistan which have their own complexities.​

• Reading and embedding the local regulations of each market into the overall framework rather than relying purely on global benchmarks.​

• Accepting that policies, thresholds, and processes will need to differ by country, and sometimes by business line, to remain both compliant and culturally credible.​

In practice, this means designing a global TPRM program, then tailoring its application market by market instead of exporting a rigid, central template.

Local Regulations, Culture, and Policy Design

Local realities can upend assumptions. On privacy, being compliant with a “gold standard” like GDPR does not automatically guarantee compliance with Middle Eastern regimes such as Saudi Arabia’s Personal Data Protection Law (PDPL), which may include data residency requirements and other local conditions.​

Sanctions compliance is another area where a purely global lens is not enough. While OFAC, UN, and EU lists matter, governments in the region maintain their own sanctions and criminal lists, including politically exposed persons (PEPs) and individuals with adverse media that may not appear in the global systems. A robust third‑party program has to incorporate these local lists and monitoring sources.​

Culturally, larger and sometimes tribal family structures, reliance on referrals, and a strong ethos of hospitality shape how business is done. This has direct implications for conflicts of interest and gifts and entertainment.

Finally, local language is critical: many third parties will only sign contracts in Arabic or other local languages, so compliance and legal teams need in‑house language capability and bilingual or trilingual agreements.​

Moving From Onboarding to Operational Resilience

A recurring theme was that third‑party risk programs focused only on onboarding questionnaires and periodic checks are no longer fit for purpose. In the words used during the webinar, if your TPRM program is essentially one questionnaire at onboarding, “you aren’t managing risk, you’re managing paperwork.”​

Instead, resilient organizations are building a fundamental framework to answer:

• Who are our third parties and what do they actually do?

• What data and systems can they access?

• How dependent are we on them for critical processes and customer experiences?

• What vulnerabilities do they introduce, and what is our plan if something goes wrong?​

By shifting from periodic reviews to dynamic monitoring, companies can elevate their third‑party risk framework from a back‑office control to a core driver of operational resilience. That shift allows compliance and procurement to focus their limited resources on the third parties whose failure would create material impact on customers, operations, or brand.​

Elevating TPRM Into the Boardroom

The speakers also highlighted how third‑party risk has moved from an operational concern into a board‑level discussion. Boards, they noted, are less interested in how many vendors were screened or how many questionnaires were completed, and far more interested in:​

• How well the business has been protected from downtime and disruption.

• Whether vulnerabilities have been identified and mitigated early.

• How the TPRM program has created competitive advantage and protected customers.​

To capture board attention, compliance leaders need to pilot clear programs and then report on them using meaningful analytics and KPIs, such as indicators related to third‑party incidents, resolution times, resilience of key services, and risk reduction over time. Once the conversation is framed around protection and advantage, rather than cost and friction, the boardroom narrative shifts, and support for investment in tools and people becomes easier to secure.​

Choosing Technology That Actually Fits

Automation and AI emerged as essential to scaling TPRM, but the speakers were clear that not every tool suits every organization, and not every task can or should be automated. When evaluating technology, compliance teams should first understand:​

• What capabilities the tool offers: workflow integration, screening coverage, AI features, and reporting.

• Where the screening data comes from and whether it covers all relevant markets, including local lists in the Middle East.​

• How the tool aligns with the company’s specific third‑party framework and needs.​

Only after those functional questions are answered should cost and implementation be considered. There is no “perfect” tool; rather, each company must map its requirements and then select the platform that best fits its geography, risk profile, and operating model.​

Organizations should also consider local or regional providers, particularly when on‑the‑ground support, language skills, and regional understanding can be strategic assets. Global vendors may offer scale, but time zones and limited local coverage can be obstacles when issues arise.​

AI: Operating System for the Next Era of TPRM

Artificial intelligence was described as “here to stay” and likely to act as a new operating system that will redefine each stage of the vendor lifecycle, from RFPs and due diligence to contracting and onboarding. The trajectory is towards more automation, faster cycles, and less manual bureaucracy, with AI augmenting human teams.​

However, the speakers emphasized two core responsibilities for compliance officers:

• Ensuring ethical, responsible use of AI internally, including clear AI guidelines, controlled use of customer data, and enterprise‑grade accounts.​

• Vetting third parties’ own use of AI and data governance so that external partners adhere to similar standards and local regulations.​

AI should be integrated where it can deliver defensible, high‑quality outcomes, especially for low‑risk, high‑volume tasks. But critical judgments, complex risk assessments, and regulator‑facing decisions still require human oversight. The use of AI in TPRM needs to stay within the organization’s risk tolerance and remain explainable; regulators will not accept “the AI said so” as a justification if the decision cannot be defended.​

Entering or Expanding in the Middle East: Day‑One Priorities

For organizations moving into the Middle East or maturing their programs in the region, the webinar outlined a pragmatic sequence rather than a single “P0” task. The first step is to gain a deep feel for the regulatory and macro environment in each target jurisdiction.

Once that landscape is understood, companies can:

• Formulate a regional compliance strategy tailored to the specific markets they intend to operate in.

• Establish a local legal entity where appropriate and hire a local compliance officer.

• Engage local legal counsel and begin designing an end‑to‑end risk management framework for both third parties and employees.​

From there, sharper TPRM elements can be layered on: local‑language contracts, calibrated conflict‑of‑interest and gift policies, integration of local sanctions and PEP lists, and a dynamic monitoring setup that incorporates geopolitical, financial, and ESG signals.​

Conclusion

Looking ahead, the speakers expect AI‑driven automation and, hopefully, greater regional stability to shape the future of third‑party risk in the Middle East. Closing advice for compliance leaders is to:​

• Understand how AI is changing TPRM and how it can create competitive advantage.

• Stay curious and adaptive in the face of new tools, laws, and geopolitical shifts.

• Stay human, maintaining judgment, ethics, and empathy at the core of compliance work even as technology takes on more tasks.​

In this model, third‑party risk management is no longer a back‑office screening function but a strategic discipline that combines local insight, strong governance, smart technology, and a continuous, risk‑based mindset.

Interested in listening to the full webinar, where these topics and more were explored? Our webinars are always available on-demand.