2012 Newsletter Q1 ABC Dubai

The American Business Council

IT’S ALL ABOUT

TRADE

The first quarter has been buzzing with of talk about trade in the American business community, from the surge in exports from the US to the UAE, a 36% increase over the previous year to the anti-corruption and economic sanctions seminar presented by an ABC member law firm to the recent event with US Department of Commerce, Assistant Secretary for Export Enforcement, David Mills, (co-sponsored by the Dubai Chamber) to the stunning rise in the UAE’s foreign trade to reach a record above AED 1 trillion. Recovery and optimism is the talk of the town.

INSIDE

Doing Business in the UAE excerpt  Anti-Corruption and Economic Sanctions Compliance: Facts to protect your company  Members’ Calendar

IT’S ALL ABOUT TRADE

CONTINUED

The Foreign Trade Division of the US Census Bureau announced that exports from the United States to the United Arab Emirates reached a record level of $15.89 billion in 2011, a 36% increase over exports in 2010 of $11.67 billion. The UAE is once again America’s number one export market in the Middle East North Africa (MENA) region and a top 20 destination for US goods worldwide. The previous record for exports from the US to the UAE of $14.4 billion occurred in 2008.

Trade between the US and the UAE also marked a record high of $18.34 billion in 2011. The UAE exported $2.44 billion worth of goods to the US in 2011, more than twice its export level to the US in 2010 of $1.15 billion.

Rising investment levels in the UAE across multiple economic sectors including manufacturing, aviation and technology drove the export increase from the US. Aircraft, machinery and autos topped the list of US exports arriving in the UAE in 2011. Goods manufactured in every state were exported to the UAE, with December as the highest month for exports, totaling $1.824 billion. The top US export to the UAE in 2011 was transportation equipment at $5.893 billion. Aluminum products are the single largest export category from the UAE to the US. According to Justin Siberell, US Consul General Dubai, “American businesses play a key role in the commercial life of Dubai and the UAE. American companies have for decades encountered a welcoming business climate here and have, as a result developed strong presence in many economic areas.”

As a large and growing market for US companies, the UAE’s policy of economic diversification and its ideal geographic location continue to strengthen trade links between the two countries.

Doing Business in the U.A.E.

I. INTRODUCTION A foreign company may conduct business in the UAE by operating from "off-shore" (via an agent or directly with customers), by operating in a "free zone" and by operating directly in one or more of This article will be published in the 2012 ABC Directory in its entirety.

It is supplied by ABC President's Club member

the seven Emirates (but outside of a free zone).

There are both federal and Emirate-specific laws and regulations, and there can be multiple regulatory authorities at the federal and Emirate levels.

Also, the discretionary policies, practices and procedures of these authorities supplement the official

The UAE welcomes foreign direct investment by American businesses. However, the rules and requirements for doing business in the UAE are complex and often misunderstood. This overview identifies the different ways to do business in the UAE and points out important considerations, including some important US laws and regulations that apply to operations here.

laws and regulations and can affect business to a great extent. Determining the most appropriate alternative depends on many factors, including the targeted customer base and the nature of the products or services to be offered. Set forth below is an overview of the primary methods for foreign busi-

Copyright 2012 - Fulbright & Jaworski L.L.P. The foregoing overview is not intended to substitute for legal advice on specific matters.

nesses to conduct business in the UAE, as well as a summary of several other key considerations for doing business in the UAE.

Doing Business in the U.A.E. excerpt from the 2012 ABC membership Directory

II. INDIRECT OPERATIONS – DEALING WITH AGENTS

made by or through the commercial agent.

Foreign entities generally may make private sector product

C.

Registered commercial agents are entitled to

sales from off-shore directly into the UAE without participation prevent products subject to their agency from being imported by a UAE party. In addition, UAE companies with foreign own-

into the UAE if the commercial agent is not the consignee,

ership may import and resell goods upon obtaining the appro-

unless the UAE Council of Ministers has exempted the subject

priate licenses. However, only UAE nationals (or entities wholly products from application of the Commercial Agency Law. This -owned by UAE nationals) may conduct certain "commercial

potential exemption of designated products was confirmed as

agency activities" as a registered commercial agent, with its

part of the 2006 Amendments. Products currently excluded

associated rights and privileges.

from the application of the Commercial Agency Law include the

The UAE Commercial Agencies Law, Federal Law No. 18 of

following foodstuffs and related products: dry and condensed

1981, as amended by Federal Law No. 14 of 1988, and Federal

milk, frozen and canned vegetables, children's foodstuffs, milk,

Law No. 13 of 2006 (the "2006 Amendments"), and Federal Law poultry, cooking oil, rice, flour, fish products, meat and its prodNo. 2 of 2010 (the "2010 Amendments") (collectively, the

ucts, tea, coffee, cheese, pasta (macaroni, vermicelli), sugar

"Commercial Agency Law"), regulates and governs the appoint- and diapers. ment of registered commercial agents, sales representatives and distributors in the UAE. The Commercial Agency Law is

D.

A principal may not terminate or fail to renew

supplemented by, inter alia, the UAE Commercial Transactions

the agency agreement unless there is a material reason justify-

Law, Federal Law No. 18 of 1993 (the "Commercial Code"), im-

ing such termination or non-renewal. Either party is entitled to

plementing regulations, custom and practice. Together, the

claim compensation for damages suffered and losses incurred

Commercial Agency Law and the Commercial Code provide the

due to termination or non-renewal of a registered commercial

primary regulatory framework for agency relationships through agency. In practice, this is a benefit to the commercial agent which foreign businesses provide products and services in the

only.

UAE. The Commercial Agency Law is a federal law that applies

Furthermore, commercial agents are not limited to seeking

throughout the UAE and grants registered commercial agents

remedies under the Commercial Agency Law. For example, a

formidable statutory rights as detailed below. Certain public

commercial agent might also claim damages for improper ter-

sector sales require the involvement of a registered commercial mination or non-renewal pursuant to the Commercial Code. agent. Otherwise, a foreign company can choose alternative means of selling into the UAE that do not involve a registered commercial agent.

E.

A registered commercial agent can preclude

the foreign principal from appointing a replacement registered agent even if the registered agency was for a fixed term that

A.

Registered commercial agents are entitled to

has expired, unless the former agent consents or the principal

an exclusive territory covering at least one Emirate for the

obtains a favorable decision from the specialized agency dis-

specified products or services.

putes committee or a court in the UAE.

B.

Unless otherwise agreed, registered commer-

In addition, the Commercial Agency Law provides that commer-

cial agents are entitled to receive commissions on sales in their cial agency agreements shall be governed exclusively by UAE designated territory irrespective of whether such sales are

law notwithstanding any provision to the contrary in the

agency agreement. Furthermore, UAE Cabinet Resolution No. 3 III. DIRECT OPERATIONS of 2011 Concerning the Commercial Agencies Committee re-

In addition to a foreign entity establishing an "indirect" busi-

quires parties to submit their disputes to a specialized agency

ness presence in the UAE via an agency relationship, there are

disputes committee that has original jurisdiction over disputes

several alternatives by which a foreign entity may be licensed

regarding registered commercial agency agreements, including

to undertake specified activities on a direct, permanent basis in

questions of agency de-registration. The committee may refer

the UAE. The UAE Commercial Companies Law, Federal Law

disputes to the UAE courts, and parties may also challenge in

No. 8 of 1984, as amended (the "Companies Law"), provides for

court decisions made by the committee.

a number of different corporate structures. The primary alter-

e

natives for foreign entities to establish direct business operaAccording to the Commercial Agency Law, a commercial agent

tions in the UAE (outside the free zones) are (i) registration of a

has to register its agency agreement with the UAE Ministry of

branch office and (ii) incorporation of a limited liability com-

- Economy and Commerce (“Ministry of Economy�) to claim the benefits of the Commercial Agency Law. But there have been instances where some courts have applied the Commercial Agency Law to unregistered commercial agency agreements in certain contexts. The 2006 Amendments had led the international business community to expect a trend towards more liberalization in this area, but, the 2010 Amendments were a step in the opposite direction and a clear signal of greater, or at least continued, protectionism for UAE commercial agents.

The statutory protections for commercial agents under the Commercial Agency Law create an obvious disincentive to foreign entities to do business through registered commercial agencies if alternative means are available. The three most common alternative means are: (i) to sell directly from overseas (i.e., "off-shore") to the end-user customer; (ii) to sell

pany with a UAE national "partner".

By establishing a direct business presence in the UAE, a foreign entity is permitted to engage in specified activities as licensed by the relevant UAE authorities. Except for certain "free zone" registrations and operations discussed below, entities engaging in commercial activities in the UAE must be separately registered and licensed at the federal UAE level (subject to exceptions for certain branch offices, e.g., see Section III.A below), as well as in each Emirate where they wish to operate. Commercial entities must also be registered with, inter alia, the Immigration Department of the UAE Ministry of Interior (the "Immigration Department") and the UAE Ministry of Labor and Social Affairs (the "Ministry of Labor") to secure employment/residency visas (if necessary) and work permits for their personnel.

A.

Branch Office

through an agent other than a registered commercial agent;

Through registration of a branch office, a foreign entity can

and (iii) to establish a direct legal presence in the UAE.

establish, on a wholly owned basis, a direct business presence to perform specified activities in the Emirate where the branch

Evaluating statutory protections and other commercial and

is licensed. No UAE participation is required other than utilizing

legal principles and practices are important not only in negoti-

the services of a UAE national "local agent" to handle certain

ating new arrangements with UAE distributors, representatives administrative matters, as described below. Such a branch ofand agents, but also in ending any such relationships. Invaria- fice is not a separate and distinct legal entity from the foreign bly, termination of agency relationships is contentious, time

company. Rather, the foreign company itself is licensed locally

- consuming and expensive, even if the agent is not a registered

to undertake specified activities in the UAE through its branch

commercial agent.

office. The foreign company is fully responsible for the liabilities of the branch office.

Doing Business in the U.A.E. excerpt from the 2012 ABC membership Directory

A branch office may conduct only those activities specified in its

be seen how significantly the law will expand the ability of free

license. The issuance of licenses to branch offices involves dis-

zone entities to operate outside the free zones in Dubai proper.

cretion on the part of the governmental authorities, including with respect to whether they believe the foreign company is one they desire to have operating in the UAE and in the applicable Emirate, and the types and scope of activities they will allow.

Under Ministerial Resolution No. 208 of 2011, a foreign company must deposit a sum of Dhs. 50,000 with the Ministry of Economy for each branch office to be opened in the UAE. Previously, foreign companies were required to submit a bank guar-

A representative office is a type of branch office that is not sup-

antee for this amount from a bank operating in the UAE.

posed to engage in sales, services or any other type of commer-

According to the Companies Law, a foreign entity is required to

cial activity. Rather, a representative office is only supposed to

appoint a UAE national "local agent" for its branch office. How-

act as a liaison or administrative office to promote the com-

ever, for certain registrations, such as branches providing ser-

pany’s products and services and to facilitate business between

vices to the military or financial services, the relevant special

the foreign principal and its customers (or intermediaries).

purpose regulatory authority may choose to serve as a nominal

Some direct contact with customers is permitted, but employees local agent. This determination is made by the relevant regulaat a representative office are not authorized to engage in sales or perform services. The approvals for representative offices generally can be obtained more quickly and with less governmental scrutiny than for other types of branch offices.

Although exceptions were granted in the past, pursuant to Ministerial Resolution No. 377 of 2010 (“Resolution No. 377”) branch offices may not engage in "trading" activities (i.e., buying and/or importing for resale in the UAE). Thus, branch offices are not allowed to engage in trading, but this should not affect trading licenses previously granted to branch offices.

Resolution No. 377 authorizes free zone entities to form branch offices in the UAE, subject to satisfying licensing requirements.

Further, under Resolution No. 377 branch offices are not required to register at the Federal level (i.e., the Ministry of Economy) to perform a special purpose contract with a government party in the UAE if the requisite license corresponding to the contract is obtained from the relevant Emirate licensing authority.

Dubai Law No. 13 of 2011 Regulating Economic Activities in Dubai (“Dubai Law No. 13”) also contemplates the possibility of free zone entities establishing branch offices outside the free zone in Dubai “proper.” Dubai Law No. 13 also provides that free zone entities may be authorized to engage in their licensed activities in Dubai proper, but under certain terms and conditions to be issued by the Executive Council. Such terms and conditions have not yet been clarified. Consequently it remains to

tory authority on a case by case basis.

The local agent is not permitted to own equity in the branch office. Similarly, the local agent generally may not interfere in the substantive management of the branch office, unless otherwise agreed given that the terms of the agency relationship are a matter of contract between the parties. In practice, a foreign entity typically contracts with a local agent to provide specific administrative services such as communicating with government departments to process the registration and licensing renewals for the foreign company, and processing visas and work permits for its personnel. The level and form of compensation paid to the local agent varies widely in practice and is a contractual matter to be agreed between the local agent and the foreign entity.

There is no specific level or form of compensation stated under UAE law. Some local agents charge a fixed annual fee, while others charge a percentage of revenue, in which case a cap on compensation is advisable. As for all foreign intermediaries, US companies should perform FCPA due diligence on the local agent candidate.

B.

Limited Liability Company

UAE limited liability companies ("LLCs") must have a minimum of two and a maximum of 50 equity owners and a minimum of 51% equity ownership by UAE nationals (or entities wholly-owned

by UAE nationals). In this summary, we refer to such equity owners as "partners", but parties commonly use "shareholder" and "partner" interchangeably. The minimum capitalization

required by the Companies Law for a limited liability company

ther the registered charter document or the Companies Law,

(e.g., Dhs. 150,000) was abolished in June 2009 pursuant to Fed- the latter likely will control. eral Law No. 1 of 2009 on Amending Certain Provisions of Fed-

Parties have implemented a variety of measures (some lawful

eral Law No. 8 of 1984 Concerning Commercial Companies. The and some not) trying to ameliorate the limitations on foreign current requirement is to have sufficient capital for the busi-

ownership of LLCs imposed by the Companies Law. Although

ness, which is to be determined by the partners. However, in

the Companies Law requires at least 51% of the capital of an LLC

practice, the authorities have discretion to impose their own

to be owned by UAE nationals, it also permits profits and losses

requirements (e.g., Dhs. 300,000 in Dubai, and also minimum

to be split by the LLC partners as they may agree. The various

capitalization requirements for certain types of activities, such

Emirate licensing authorities impose restrictions in practice, of-

as industrial and manufacturing operations). As a practical mat- ten limiting to 80% the profits allocable to the foreign partners. ter most businesses require a certain amount of capital to operate, often greater than Dhs. 150,000. Also, there is risk that having no minimum amount of capital could potentially expose partners to greater personal liability due to insufficiently capitalizing the business. In any event, it will take time to assess the practical impact of eliminating the minimum capitalization requirement for an LLC.

Some foreign parties have tried to engage UAE nationals to participate in LLCs as mere "sponsors" or "nominees" (often referred to colloquially as "silent" or "sleeping" partners) solely for the sake of appearing to satisfy the UAE national ownership requirements imposed by the Companies Law. Such arrangements typically commit the UAE national to relinquish all profits, voting rights and other rights of ownership to the foreign party,

Recent press reports indicate that the UAE Council of Ministers

often by a "side agreement" not reflected in the registered char-

has approved a new Companies Law that will relax existing for-

tered document. Such arrangements are not legal under the

eign ownership restrictions (e.g., permit more than 49% foreign

Companies Law, and are criminal violations under Federal Law

ownership in an LLC), at least for certain sectors, and impose

No. 17 of 2004 on Combating of Commercial Concealment

minimum corporate governance standards. However, as of

(the "Commercial Concealment Law"), which proscribes such

early 2012 the new law has not been published in the official

arrangements and imposes stringent penalties on the UAE na-

gazette.

tional "concealing party" as well as the foreign "concealed

Pursuant to the Companies Law, LLCs may be licensed to engage in a wide range of commercial activities, except for banking, insurance and the investment of money for third parties. For example, an LLC may engage in trading. An LLC usually is the preferred vehicle for a joint venture between a foreign party and a UAE party.

party". Enforcement of the Commercial Concealment Law, which originally was to be effective in November 2007, was deferred until December 31, 2009 by UAE Cabinet Resolution No. 229/12 of 2007. We are not aware of any subsequent law or resolution deferring the implementation of the Commercial Concealment Law or issuance of any implementing regulations.

Thus, it would be advisable to assume that the Commercial Con-

The creation, capitalization, and governance of an LLC is gov-

cealment Law took effect as of January 1, 2010, although there

erned by the Companies Law and by its charter document (e.g.,

have not been reports of active public enforcement of that law.

Articles or Memorandum of Association), an Arabic language

Even if the authorities choose not to prosecute violators, foreign contract among the LLC partners that is registered with the local parties need to understand that reliance on the types of arauthorities. This charter document usually is supplemented by rangements described above may be misplaced due to serious other agreements, such as joint venture agreements. The Com-

questions about their enforceability and the potential accountpanies Law gives the partners a great degree of latitude to nego- ing and disclosure complications related to securities matters for tiate the terms for governance of their LLC. But, in the event of the foreign partner and merger and acquisition activity relating a conflict between any such supplemental agreements and ei-

to the LLC.

Doing Business in the U.A.E. excerpt from the 2012 ABC membership Directory

IV. OPERATION IN A UAE "FREE ZONE"

ent licensing or some other legal arrangement permitting the

UAE free zones present a means to conduct business within the

specific business activities outside the free zone. However, em-

territory of the UAE, but not within its import and customs

ployees working for a free zone branch or company may live

boundaries. Such free zones tend to be more "user-friendly"

anywhere in the UAE.

and conducive to foreign investment than in the UAE proper.

For example, the relevant documents to establish and conduct business in a free zone are in English. Early free zones included the Jebel Ali Free Zone ("JAFZ"), which is a seaport and industrial facility, and the Dubai Airport Free Zone ("DAFZ") at the Dubai airport. UAE free zones account for a significant portion of foreign commercial activity in the UAE. These free zones have been instrumental in positioning the UAE as the commercial hub of the Arabian Gulf and as a leading international transshipment center.

Other Emirates also have established free zones. Sharjah has a

seaport free zone (Hamriyah Free Zone) and an airport free zone (Sharjah Airport International Free Zone). Ras Al Khaimah, Fujairah, Ajman and Umm Al Quwain also have free zones. Abu Dhabi has only recently begun to establish free zones. Abu Dhabi has a media free zone called Twofour54, Masdar City, which is intended to become a leading global centre for renew-

able energy research, development, implementation and investment, and Abu Dhabi Airports Company Skycity which operates Abu Dhabi Airport Free Zones at the three main airports in Abu

Each free zone has its own special purpose business regulatory

Dhabi. In addition, Abu Dhabi has set up ZonesCorp to establish,

schemes, but the rules and practices for business activities are

manage and operate specialized economic zones within Abu

quite similar from zone to zone. Among the investment incen-

Dhabi.

tives generally available in the free zones are 100% foreign ownership, guaranteed income tax holidays and no restrictions on

There is a wealth of information available on the Internet about

repatriation of capital and profits. Moreover, as the names im-

the various free zones in the UAE.

ply, there generally are no customs or other import duties or taxes with respect to imports into or exports out of the various free zones, provided that goods are not then imported into the UAE proper.

Free zones generally permit: (i) the registration of whollyowned branch offices of foreign companies; or (ii) the incorporation of single or multiple shareholder corporate entities with 100% foreign ownership. The types of activities usually permit-

V.

OTHER KEY CONSIDERATIONS A.

Monetary Policies

There are currently no foreign exchange control laws or other legal restrictions on the repatriation of capital and earnings.

Currently, the UAE Dirham is pegged to the US Dollar and the exchange rate has been approximately US $1 = UAE Dirhams 3.67 for many years.

ted in the various free zones are trading, industrial, and service

The UAE Central Bank has adopted money laundering regula-

activities, although there are some exceptions.

tions that impose certain restrictions, including reporting obliga-

Some free zones follow the economic cluster model focusing on particular types of industries or services, such as: (i) Dubai Technology and Media Free Zone ("TECOM," which includes Dubai Internet City, Dubai Media City, Dubai Knowledge Village, Dubai International Academic City, Dubai Healthcare City and others); (ii) Dubai International Financial Centre ("DIFC"); (iii) Dubai Multi Commodities Centre and Jumeirah Lakes Towers; and (iv) Dubai Silicon Oasis. It is important to note that free zone registrants may not engage in business in the UAE proper absent independ-

tions on certain cash transactions. In addition, the Dubai Financial Services Authority acts as an independent regulator for certain entities that are registered in the DIFC. B.

Taxes

There are no special purpose income tax laws or regulations, corporate or individual, issued at the UAE federal level. At the local Emirate level, most of the Emirates have issued corporate income tax decrees in some form. However, to date such tax decrees have not been enforced and income taxes generally

have not been imposed by any of the Emirates except with re-

Real Estate

spect to: (i) certain companies engaged in the production of oil, As is the case in many Middle East countries, real property is gas and/or petrochemicals; and (ii) foreign bank branches. Also, afforded special "guarded" status in the UAE. Although the UAE currently there are no personal income tax laws enacted in any

Constitution vests legislative authority over real estate owner-

of the Emirates.

ship with the UAE federal government, to date no UAE federal

e There are also no withholding taxes, no payroll taxes, and no value-added taxes or sales taxes, except with respect to certain items such as alcohol and tobacco. But government authorities may be seeking additional sources of revenue. As described in Section V(F) below under Labor and Employment, the government is now collecting payroll data that would enable it to im-

- plement a payroll tax. Also, it has been rumored that a VAT will be implemented in the future, but no developments in this regard have occurred as of early 2012. There are taxes on items

, such as services at hotels, as well as residential and commercial

-

D.

premises leases (e.g., annual fees collected based on the value of a lease).

real estate law has been passed. Federal Law No. 5 of 1985 Regarding the Civil Transactions Law (the "Civil Code") includes provisions relating to real estate, but not with respect to fee ownership. Thus, land ownership restrictions in the UAE are generally established by rules and practices on an Emirate-byEmirate basis. In particular, each Emirate maintains its own policies and practices with respect to land ownership by non-UAE nationals. In this regard, there have been significant legislative and practice developments in nearly all of the Emirates. These developments are expected to continue for real estate matters throughout the UAE. The following provides only a brief overview of the landscape in Dubai and Abu Dhabi.

Persons subject to tax in other jurisdictions, such as persons

Look for the complete article in the 2012 ABC Membership

subject to US tax on worldwide income, should consult their tax

Directory, with topics including:

advisors regarding the application of such taxes to their activities in the UAE. The UAE has entered into tax treaties with a number of countries.

C.

Intellectual Property

There are three primary federal laws related to the protection of intellectual property rights in the UAE, namely: (i) the UAE Trademark Law, Federal Law No. 8 of 2002, which amended Federal Law No. 37 of 1992; (ii) the UAE Copyright Law, Federal Law No. 7 of 2002; and (iii) the UAE Patent Law, Federal Law No. 17 of 2002.

These primary intellectual property laws are supplemented by other legislation, including Federal Law No. 4 of 1979 Regarding the Prevention of Fraud and Deception in Commercial Transactions, the Commercial Code, and various ministerial resolutions. In addition, it is important to note that the UAE is a member of many international treaties, including treaties related to intellectual property such as the Berne Convention. Also of interest, the UAE has a federal consumer protection law, Federal Law No. 24 of 2006 Concerning the Protection of Consumers. Various e-commerce related laws have also been implemented at the federal level as well as within several individual Emirates.

Dubai Freehold Property Abu Dhabi Freehold Property General Freehold Property Issues Tenancy Issues Financial Records and Accounting Labor and Employment Immigration US and Other Regulatory Issues Export Controls and Sanctions Anti-Corruption US Anti-boycott Regulations Reporting Financial Accounts Dispute Resolution Choice of Foreign Law and Venue Enforcement of Foreign Court Judgments Enforcement Of Domestic And Foreign Arbitration Awards DIFC Courts Expanded Jurisdiction Personal Conduct

Anti-corruption and Economic Sanctions Compliance: Learning the facts to protect your company

Seminar presented by ABC member law firm, Chadbourne & Parke, examined the relevance of U.S. anti-corruption laws and sanctions for U.S. and non-U.S. corporations and individuals On March 28, the ABC in partnership with member law firm Chadbourne & Parke, held a seminar on international anti-corruption law and economic sanctions Chadbourne's MENA practice draws upon the combined experience of lawyers in the corporate, litigation, securities, project finance, energy, tax, intellectual property, real estate, employment law and trusts and estates areas. In addition to offices in London, Dubai and Istanbul,

compliance at The Palace Hotel in Dubai.

The seminar was attended primarily by ABC members as well as guests from local and foreign companies,

Chadbourne serves clients in the region

banks, financial institutions and leading law firms and

through strong relationships with local

provided insight and analysis regarding the implica-

law firms in Lebanon, Kuwait, Saudi Arabia, Bahrain, Oman, Qatar, Jordan, Egypt,

tions of the U.S. Foreign Corrupt Practices Act (FCPA),

Tunisia and Morocco.

the UK Bribery Act, economic sanctions and antimoney laundering regulations in the U.A.E.

Speakers, Scott Peeler, left photo, and Ramsey Jurdi, right photo, give the facts on anti-corruption and sanctions compliance.

The seminar is one of a series on anti-corruption and economic sanctions presented in Istanbul and Beirut by Chadbourne’s Dubai associate Ramsey Jurdi (and ABC board member) and Scott Peeler, Chadbourne New York partner in response to the fast expanding needs of corporations in the region.

"Exciting developments are taking place in the U.A.E. and the Middle East," said Chadbourne partner Scott Peeler. "In particular, foreign companies doing business in the Middle East are facing tougher scrutiny and penalties than ever before. Companies and their employees and managers need to fully appreciate the risk of non-compliance, and must implement the strictest anti-corruption controls where they are needed."

"Anti-corruption laws and economic sanctions are important topics in the region," added Jack Greenwald, head of Chadbourne's Dubai office. "The seminar in Dubai provided the members of the ABC the opportunity to obtain important information and to benefit from Chadbourne's experience and expertise in these fields."

MEMBERS’ CALENDAR

Don’t miss a great day of golf on Dubai’s premiere course Dubai Creek Golf & Yacht Club April 21 The 21st Annual ABC Golf Tournament Driven by

For details and to reserve your place go to our online calendar at www.abcdubai.com

ABC is on the move!

Watch for exact details of the transition in the coming weeks, but our offices will be moving to

The Emarat Atrium Building Sheikh Zayed Road

MEMBERS’ CALENDAR

SAVE THE DATE The ABC Business Forum May 8, 2012 Join us as we investigate the following business sectors with a view to producing relevant white paper on ways to increase opportunities for American Business. * Healthcare & Insurance * Banking & Finance * Hospitality, Travel, & Tourism * Real Estate Transportation *Education * Engineering, Construction, & Project Management * Legal Affairs * Energy * Technology

MEMBERS’ NEWS

Tom Friedman and The Middle East’s Role on the New Silk Road IHT Global Conversation: Dubai May 2nd, 2012 Armani Hotel To celebrate its 125th Anniversary, the International Herald Tribune is convening “The Global Conversation,” a series of events bringing together high profile speakers and IHT journalists for an evening of dinner and thought-provoking debate. Join us in Dubai, and hear The New York Times’ Foreign Affairs Correspondent Thomas Friedman discuss whether the Middle East can focus on new economic opportunities through this period of regional political upheaval, while patterns of global trade and capital flows are changing dramatically.

Special discount for members code GCDAB Visit https://www.eiseverywhere.com/39008?discountcode=GCDAB for more information or to register.