Welcome back to the podcast, bribes, swindle, or steel.

I'm Alexandra Rogge and today we're talking about the United Arab Emirates with my guest, Charles Lobach.

Charles is a partner in a Fridi and Angel's Dubai office.

He has been practicing as a legal consultant

in the UAE for over 30 years. Charles advises on a wide range of issues and for our purposes

specializes in US, UN and other sanctions and the USFCPA in similar bribery prohibitions.

Charles, thank you for joining me. Most welcome.

Why don't you start by talking about the level of commercial bribery, whether real or perceived, in the UAE?

Perceptions and reality are somewhat divergent. I guess the main factor to bear in mind is that the level of bribery

in the real world varies tremendously from sector to sector. And it's not the same in the UAE as it is

in other parts of the world. Generally, when you look at these OECD surveys of corruption, military, and oil and gas rate very high.

But I would have to say in the UAE, probably the oil and gas sector and the defense sector

among the cleanest. There's very little toleration of corruption. The buyers, the consumers of oil and gas services and of defense products,

they're very concerned about the appearance of propriety and about the actuality of propriety.

And they want to make sure they get full value for what they're paying.

And bribery in those sectors is kept to a minimum because the buyers themselves,

the government purchasers, are vigilant about corrupt activity and they are taking all kinds of proactive measures to stamp it out.

Not just contractual measures with their suppliers, but they actually police what's going on.

However, in other sectors, there probably is a little bit more corrupt activity than

you'd like to see. Here in the UAE, probably the construction sector has the most, just because

there are so many parties involved, so much scope for exercise of discretion, and just, I think

players in the sector tend to expect it. They expect to see

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