Mitigating Corruption Risk in the Middle East (Part One of Two)

The Middle East lures businesses and investors with eye-popping wealth, rich natural resources and an almost insatiable appetite for growth.  But the region presents a panoply of challenges for those wishing to do business there without running afoul of both American and local anti-corruption laws.  A prevalence of state-owned entities and business-minded royal families; laws requiring third-party facilitators in transactions; and a culture that embraces gift-giving are only some of the corruption risks in the region.  These challenges were recently addressed at a Strafford Publications panel featuring Tom Best, a partner at Steptoe & Johnson in Washington, D.C.; Marc Alain Bohn, counsel at Miller & Chevalier in D.C.; John Vincent Lonsberg, a partner with Baker Botts based in Dubai, U.A.E.; and Daniel P. Chung, of counsel with Gibson Dunn in D.C.  This article series covers some of the insights from the panelists.  This first article addresses the diverse cultural and legal factors that a company needs to be aware of when doing business in the region.  The second article will focus on three specific areas of corruption risk and strategies for mitigating those risks.  See also “Corruption and the Arab Spring: Compliance Implications for International Companies,” The FCPA Report, Vol. 1, No. 4 (Jul. 25, 2012).

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