FCPA Risks in the Gulf Region

FCPA Investigation - the Middle East

For a major US law firm, Nardello & Co. conducted an investigation of a senior executive at a government-owned company in the Persian Gulf. The law firm's client, a multinational conglomerate, had been approached by the executive for payment in return for facilitating its sale of equipment to the government-owned company. 

Through a series of confidential source inquiries, we determined that the executive had relatives who were situated close to the political center of power. Additionally, a review of Arabic and English language public sources and inquiries with country experts revealed that this country's government had been clamping down on corruption following a series of local scandals. Based on our findings and our determination that an exchange for services could be in violation of a number of international laws, including the US FCPA, the law firm advised its client to withdraw from the proposed sale and discontinue its dealings with the corrupt senior executive.