Welcome to the Anti-Bribery and Corruption Training. This video contains audio and a transcript. To listen to the audio, please use your headphones or adjust your speakers.
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Review the course objectives and tips on how to navigate this course.
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This course is divided into 5 topics and an end-of-course assessment.
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Preventing bribery and corruption requires vigilance and the ability to recognize potential warning signs. There are a range of indicators and red flags that may suggest unethical practices are taking place, and we all need to be proactive in identifying them to mitigate their associated risks. If you witness any of these red flags or indicators, you are encouraged to speak up and report them to the relevant whistleblowing channels here at the bank.
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Now let’s meet bank employee Ahmad, who’s taking an important phone call.
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In response to a rapid increase in cybercrime targeting the bank, a decision has been made to overhaul the bank’s cybersecurity infrastructure. As part of this overhaul, the bank has issued a tender for provision of a new firewall, and have invited a number of suppliers to bid.
Ahmad, who works in IT, is involved in the tender process for the new firewall. One day while in his office, he receives a phone call from an executive at Maletania Ltd, who were one of the companies invited to tender. Ahmad has dealt with this executive on numerous projects before and has developed a good business relationship with him.
While discussing the bidding process, the executive makes an offer to Ahmad. If Ahmad can prioritize Maletania Ltd.’s bid over the other companies, they will give him a small percentage of the winning bid’s value.
Fatima, who works with the risk team is faced with a challenging decision.
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The bank has recently advertised a new opening in the risk team for an experienced business analyst. They should have a minimum of 5 years’ Risk analysis experience working in a large financial organization, and possess expert knowledge of risk management practices.
Fatima, who’s one of the bank’s Risk Officers, has been handed the responsibility of overseeing the hiring process. Her nephew, Habib, has just graduated from university with a business degree and has asked Fatima to keep him in mind for the role.
While Fatima is aware of Habib’s lack of experience and relevant skills, there is an air of expectancy among her family that Habib should get the job.
Feeling the pressure Fatima agrees to give Habib the job. She advises him that they will go through the Bank’s regular interview process, but in the end the job will be his.
Bribery incidents typically involve a number of different people. Some of the main roles are outlined here.
Bribee
Any public servant who solicits, accepts, or receives for himself or for others a gift or payment of any sort, or a promise thereof, as a consideration for performing any of his office duties or an alleged office duty, even if the action taken is legitimate.
Briber
Any person who promises, offers, or grants a gift to a Bribee.
Mediator/Accomplice
Any person who is assigned by the Bribee or the Briber to take a bribe and knowingly accepts the same. Any person who knowingly agrees, incites or assists in committing such offenses shall be considered an accomplice if the offense is perpetrated as a result of said agreement, incitement, or assistance.
The main objectives of the Strategy are to:
The National Committee for the Protection of Integrity and Combating Corruption (now replaced by the Oversight and Anti-Corruption Authority (Nazaha) since 1432H (2011 AD), drives the implementation of these objectives.
It oversees execution, monitoring, and evaluation of initiatives aimed at achieving the strategy's goals.
Saudi Arabia has taken a resolute stand against corruption and bribery, and a pivotal player in this effort is Nazaha. Let’s explore the establishment, objectives, and key roles of this authority in upholding integrity and combating corruption.
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The National Anti-Corruption Authority was established in 1432H (2011) with its distinct "Statute of The National Anti-Corruption Commission," enacted on the 28th of Rajab, 1432H (February 5, 2011). This marked a significant step towards combatting corruption and enhancing transparency.
Recently the authority has underwent strategic restructuring. In 1441H (2019), King Salman bin Abdulaziz's royal decree led to the reformation of the National Anti-Corruption Authority. By merging the "Supervision and Investigation Authority" and the "Administrative Investigations," the new "Authority of Oversight and Anti-Corruption", or “Nazaha” was born, reaffirming the commitment to eradicating corruption.
Nazaha is dedicated to:
Nazaha plays a pivotal role in investigating bribery and corruption cases in the public sector. As an independent body, it is entrusted with:
SAMA plays a crucial role in addressing bribery and corruption within the financial sector. SAMA, as Saudi Arabia's central bank and financial regulator, has introduced comprehensive regulations to combat the adverse effects of bribery and corruption on the economy. These regulations are available in the Code of Conduct and Work Ethics in Financial Institutions.
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The following regulations apply when dealing with Bribery and Corruption:
The following regulations apply when dealing with Gifts and Hospitality:
Around the world a range of initiatives have been rolled out by global organizations and committees to promote transparency, accountability, and ethical practices.
| Initiative | Role |
|---|---|
| G20 Anti-Corruption Working Group (ACWG) |
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| Organization for Economic Co-operation and Development (OECD) |
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| World Bank: Anticorruption for Development (AC4D) Global Partnership |
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| United Nations Convention against Corruption (UNCAC) |
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| World Trade Organization (WTO) |
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| Transparency International Organization |
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| Arab Anti-Corruption Convention |
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Let’s take a look at a case where a bribe was used to speed up a real estate deal.
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A businessman approached three former employees of a local bank requesting that they finalize the procedures for a real estate financing request. The businessman offered the employees SR 210,000 as a bribe for them to fulfill his unlawful request.
The employees accepted the bribe but were foiled in 2023, when the Saudi Central Bank discovered irregularities in the transaction. They were subsequently apprehended and detained along with the briber.
There are two different forms of bribery on show here:
The former bank employees, by virtue of having worked for a banking institution, are classified as "public servants" according to Article 8, point 4 of the Saudi Anti-Bribery Law. The men violated:
Under the Saudi Anti-Bribery Law, the residents could face punishment:
Now let’s take a look at a case involving employees from the Saudi Electricity Company.
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In 2020, three Saudi Electricity Company employees were arrested for taking a 535,000 Euro bribe from a French company. To conceal the source of the bribe, and at the request of the French company, the employees transferred the funds to foreign bank accounts (money laundering). One of the employees later transferred part of the bribe from one of the foreign accounts to their own account in Saudi Arabia.
The French company even flew the employees to their headquarters in France, giving them around 30,000 Euro to cover the travel costs and expenses. The visit took place without the Saudi Electricity Company's knowledge. In exchange for the bribe, the employees would use their positions to favour the French company's products and increase purchase requests.
Moreover, one of the employees received an 800,000 Riyal kickback from local suppliers within the kingdom, by first transferring the amounts to a relative's bank account before moving it to their own account (also money laundering). This kickback was in return for securing supply contracts from the Saudi Electricity Company.
There are two different forms of bribery on show:
With the employees being public servants, they were in breach of the following articles as per Saudi Anti-bribery legislation:
For these breaches, the employees could face up to ten years in prison and a fine of up to 1,000,000 riyals for breaching Articles 1 and 5, and up to five years in prison or a fine of 500,000 riyals for breaching Article 9.
Let’s wrap up by reviewing a case where a bribe was used to bypass banking regulations.
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In 2022, two residents attempted to bribe an employee in an unspecified Saudi Bank. They offered the employee SAR 3 for every SAR 1,000 deposited in cash, in exchange for the employee not reporting the transaction to the relevant authorities.
Upon their arrest, an amount of SAR 199,000 was found in their possession. Further investigations revealed that they had previously deposited a total of SAR 7,500,000 in cash using the same bribery tactic.
The residents offered the employee a specific amount to the bank employee for every transaction they put through, which is a form of kickback.
The two residents were attempting to bribe an employee of a bank that is partially owned by the government or engaged in banking services, who is considered a "public servant" under Article 8, point 4 of the Saudi Anti-Bribery Law.
In doing so they violated the following articles:
Under the Saudi Anti-Bribery Law, the residents could face punishment:
Let’s review the key takeaways from this training.
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According to the Saudi Anti-Bribery Law, who among the following is considered a 'Briber'?
Select the correct answer and then select submit.
That’s right.
A briber is any person who promises, offers, or grants a gift to a Bribee.
That’s not right.
A briber is any person who promises, offers, or grants a gift to a Bribee.
That’s not right.
A briber is any person who promises, offers, or grants a gift to a Bribee.
That’s right.
That is not correct.
That’s not right.
According to SAMA's "Code of Conduct and Work Ethics in Financial Institutions" (Article III.D), what is the maximum value of a gift that a bank employee can accept without submitting a written disclosure form to the compliance department?
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That’s right.
1000 is the maximum value of a gift that a bank employee can accept without submitting a written disclosure form to the compliance department.
That’s not right.
1000 is the maximum value of a gift that a bank employee can accept without submitting a written disclosure form to the compliance department.
That’s not right.
1000 is the maximum value of a gift that a bank employee can accept without submitting a written disclosure form to the compliance department.
That’s right.
That is not correct.
That’s not right.
In the context of SAMA's "Code of Conduct and Work Ethics in Financial Institutions" (Article III.D), which of the following is not a criterion for an acceptable gift?
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That’s right.
Gifts should:
That’s not right.
Gifts should:
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Gifts should:
That’s right.
That is not correct.
That’s not right.
According to the Saudi Anti-Bribery Law, which of the following is considered an accomplice in bribery?
Select the correct answer and then select submit.
That’s right.
An accomplice is any person who is assigned by the Bribee or the Briber to take a bribe and knowingly accepts the same.
That’s not right.
An accomplice is any person who is assigned by the Bribee or the Briber to take a bribe and knowingly accepts the same.
That’s not right.
An accomplice is any person who is assigned by the Bribee or the Briber to take a bribe and knowingly accepts the same.
That’s right.
That is not correct.
That’s not right.
As per SAMA's "Code of Conduct and Work Ethics in Financial Institutions" (Article III.D), which type of gift is an exception and can be accepted by employees?
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That’s right.
A prize from a recognized program approved by the institution is an exception according to SAMA and can be accepted by employees.
That’s not right.
A prize from a recognized program approved by the institution is an exception according to SAMA and can be accepted by employees.
That’s not right.
A prize from a recognized program approved by the institution is an exception according to SAMA and can be accepted by employees.
That’s right.
That is not correct.
That’s not right.
According to the Saudi Anti-Bribery Law, what is the definition of bribery?
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That’s right.
A bribe is the solicitation, acceptance, or receipt of a gift or payment of any sort, or a promise thereof, as a consideration for performing an action.
That’s not right.
A bribe is the solicitation, acceptance, or receipt of a gift or payment of any sort, or a promise thereof, as a consideration for performing an action.
That’s not right.
A bribe is the solicitation, acceptance, or receipt of a gift or payment of any sort, or a promise thereof, as a consideration for performing an action.
That’s right.
That is not correct.
That’s not right.
A bank's procurement department receives three bids for a project. Two of the bids are competitive, but the third is surprisingly high. Later, it's discovered that a bank official provided the third company with inside information to ensure they win the bid by just undercutting the others. What form of corruption does this scenario depict?
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That’s right.
The bank official is involved in bid rigging, manipulating the bidding process to favor a particular supplier.
That’s not right.
The bank official is involved in bid rigging, manipulating the bidding process to favor a particular supplier.
That’s not right.
The bank official is involved in bid rigging, manipulating the bidding process to favor a particular supplier.
That’s right.
That is not correct.
That’s not right.
Which of the following is a red flag for bribery and corruption in the banking sector?
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That’s right.
An employee suddenly purchasing luxury items without a reasonable explanation is a red flag for bribery and corruption in the banking sector.
That’s not right.
An employee suddenly purchasing luxury items without a reasonable explanation is a red flag for bribery and corruption in the banking sector.
That’s not right.
An employee suddenly purchasing luxury items without a reasonable explanation is a red flag for bribery and corruption in the banking sector.
That’s right.
That is not correct.
That’s not right.
What was the significant outcome of merging the "Supervision and Investigation Authority" and the "Administrative Investigations" in 1441H (2019 AD) for the Anti-Corruption Authority in Saudi Arabia?
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That’s right.
Nazaha was established in 1441H (2019 AD) as a result of the merging of the “Supervision and Investigation Authority" and the "Administrative Investigations”.
That’s not right.
Nazaha was established in 1441H (2019 AD) as a result of the merging of the “Supervision and Investigation Authority" and the "Administrative Investigations”.
That’s not right.
Nazaha was established in 1441H (2019 AD) as a result of the merging of the “Supervision and Investigation Authority" and the "Administrative Investigations”.
That’s right.
That is not correct.
That’s not right.
Which of the following is not a responsibility of Nazaha?
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That’s right.
Organizing public events and seminars on general governance is not a responsibility of Nazaha.
That’s not right.
Organizing public events and seminars on general governance is not a responsibility of Nazaha.
That’s not right.
Organizing public events and seminars on general governance is not a responsibility of Nazaha.
That’s right.
That is not correct.
That’s not right.
