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The watch that arrived three weeks later

A subcontractor is awarded substantial works on a private construction project. Three weeks later, after the award is signed and the procurement process is closed, a courier delivers an expensive watch to the main contractor’s procurement manager. Nothing was requested. Nothing was promised. No government body is involved.

Many business owners would assume that no crime has been committed because the decision was already made. Bribery is also often treated as a public-sector issue rather than a risk between private businesses.

Both assumptions are dangerous.

UAE criminal law applies to bribery in the private sector. It also expressly covers benefits requested or accepted after the relevant act has been performed. The scenario therefore creates serious criminal exposure. Whether an offence is ultimately established will depend on evidence that the watch was given and received in return for the award, together with the knowledge and intention of those involved. Calling it a thank-you gift does not determine the legal position.

Private-sector bribery is a criminal offence

Under UAE anti-bribery law, a person who manages or works for a private-sector entity or establishment commits an offence if they request, accept, take or agree to receive an undue gift, benefit or advantage, directly or indirectly, for themselves or another person, in return for performing or omitting an act connected with their duties or acting in breach of those duties.

It is a separate offence to promise, offer or give the advantage. The law reaches both sides of the transaction. It may apply to directors, procurement managers, employees and consultants, as well as suppliers, subcontractors, agents and commercial counterparties.

The prescribed punishment includes temporary imprisonment for up to five years and a fine equal to the value of the benefit, subject to a statutory minimum. A foreign national sentenced to custody is also generally subject to deportation, subject to limited statutory exceptions.

A bribe is not limited to cash

The law uses broad language covering gifts, benefits and advantages. A bribe may therefore take the form of a watch, holiday, accommodation, school fees, an opportunity for a relative, a contract awarded to a connected person, cancellation of a debt or excessive entertainment.

Nothing necessarily has to change hands. A promise or offer may be sufficient. Because the giver’s offence includes making an offer, the offence may be complete even where the recipient refuses it. An attempt is also punishable in the same manner as the completed offence.

The advantage does not need to be paid to the employee personally. Routing it to a spouse, relative, friend, company or another nominated person does not remove the risk. The central question is whether the advantage was intended as the price or reward for an act, omission or breach of duty.

There is no safe monetary threshold

There is no general amount below which a private-sector gift is automatically lawful. UAE law does not create an AED 500 or AED 1,000 safe zone for gifts and hospitality.

Value is relevant evidence, but timing, frequency, concealment, the recipient’s role and the commercial matter under consideration may be more significant. A modest gift delivered while a tender, payment approval, variation, inspection or dispute is active may create more risk than a more valuable item provided in a genuinely neutral setting. Purpose and knowledge are usually inferred from messages, timing, expense claims, approval records and the parties’ conduct.

A gift after the event may still be a bribe

One of the most important features of private-sector bribery law in the UAE is that it covers a request, acceptance or promise made after the relevant act or omission has occurred. A benefit described as a reward for work already completed is therefore not automatically safe.

A genuinely unsolicited gift sent without a corrupt purpose is not automatically criminal merely because it follows a favourable decision. The recipient’s conduct will nevertheless matter. Accepting, concealing or retaining a valuable personal benefit from a successful bidder may support an inference that it was understood as a reward for the decision.

It is also not a complete answer for the recipient to say that the gift would not have changed the outcome. The law expressly prevents a private-sector recipient from avoiding liability merely by claiming that they never intended to perform, or refrain from performing, the act for which the benefit was requested or accepted.

Agents, intermediaries and companies are also exposed

Liability is not confined to the giver and recipient. A person who knowingly mediates between them in arranging, requesting, offering or receiving the bribe may commit a separate offence. An administrator who innocently books a courier is not automatically liable.

The company itself may also face criminal liability where an offence is committed by its representatives, directors or agents acting on its behalf or in its name. This may lead to a substantial corporate fine, in addition to prosecution of the individuals involved.

Handling, transferring or disguising the proceeds may also create money-laundering liability where the required knowledge and intention are present. A person who actually knows that a crime has occurred may also face liability for failing to report it, subject to the statutory conditions and exemptions. Treating the issue solely as an internal disciplinary matter may therefore be inadequate.

Bribery offences also have unusually long consequences. The criminal proceedings, the sentence imposed and connected civil claims are not extinguished merely by the passage of time.

When government is involved

The risks increase where the recipient is a public official or a person entrusted with a public service. The definition may extend beyond ministries to certain government-owned entities and persons performing delegated public functions.

Public-sector bribery carries heavier custodial exposure for the official receiving the benefit. Trading in real or alleged influence to obtain an improper advantage from a public authority is also separately criminalised. Government entities may permit limited symbolic promotional gifts through designated channels, but those rules are not criminal-law safe harbours. A branded item delivered through the correct channel can still be a bribe if it is provided in return for an official act.

What a sensible business should do

An effective gifts and hospitality policy does not need to be complicated. It should contain a clear approval threshold, a register of gifts given and received, and a blackout rule while a tender, bid, payment approval, licence, inspection, variation or dispute is active.

Hospitality should have a genuine business purpose, remain proportionate, involve appropriate representatives from both sides and be documented when it occurs. Agreements with agents, introducers, consultants and PRO service providers should include anti-bribery warranties, audit rights and termination rights. Training should focus on sales, procurement, finance, project management and administrative teams.

UAE law does not provide a statutory compliance-programme defence. A policy will not erase an offence. A properly implemented programme can prevent misconduct, demonstrate the company’s position, support an investigation and assist mitigation. Bribes and other unlawful payments are also not deductible for UAE corporate tax purposes.

If a concern arises, the business should preserve relevant evidence, stop further payments, limit unnecessary internal discussion and obtain UAE legal advice promptly. Early involvement of a UAE litigation lawyer or legal consultancy firm experienced in corporate investigations can help assess reporting duties, protect evidence and avoid steps that worsen the company’s position.

A limited reporting exemption may protect a briber or intermediary who reports the offence before it is discovered. It does not extend to the recipient, and any report requires careful legal assessment.

The line worth holding

Generosity and hospitality remain normal parts of business in the UAE. The legal risk begins when a personal benefit is connected with a commercial decision, concealed from the company or incapable of being explained by a legitimate business purpose.

The safest question is not whether the gift is customary, affordable or described as a courtesy. It is whether everyone involved would be comfortable seeing its purpose, value, timing and approval explained to a prosecutor.

Note: This article is a general discussion of UAE federal law as applicable to onshore arrangements. It reflects Federal Decree by Law No. 25 of 2025 Promulgating the Civil Transactions Law, which entered into force on 1 June 2026. It is not legal advice and should not be relied upon for a specific project or dispute.

About the author

Shoeb Saher is a UAE-based legal counsel, an Advocate in India and a Solicitor of England and Wales. He holds an LL.M. from the University of Birmingham Dubai and has practised in the UAE since 2008. He is the founder of Economic Law Partners and previously spent approximately seven years with Baker McKenzie Habib Al Mulla. Shoeb advises founders, family businesses, developers, contractors and international companies on corporate and commercial matters, M&A, shareholder arrangements, construction and development contracts, financing structures, disputes and cross-border transactions. He has advised on transactions with an aggregate value exceeding AED 5 billion and regularly writes on practical UAE legal issues affecting businesses, investors and project participants.

Shoeb can be contacted at [email protected]

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