Legislation: The UAE ratified the United Nations Convention against Corruption in February 2006. Criminal penalties for official corruption are provided by law and the government has implemented these regulations effectively. According to the US Department of State 2009, there is no law requiring officials to disclose their assets. Access to government information is ensured by law; however, the provision is poorly implemented. The US Department of State 2009 in fact reports that requests for access are usually not answered. The UAE implemented a body of anti-money laundering legislation at the end of 2001, and has strengthened its legal authority to combat terrorism and terrorist financing by passing Federal Law No. 1 2004 on Combating Terror Crimes. The UAE also enacted Federal Law No. 2 2006 on Cybercrimes, which contains articles dealing with money laundering and terrorist finance, as reported by the US Department of State 2009. According to the law, public officials guilty of embezzlement face a prison sentence of minimum five years if the crime is committed in connection with counterfeit goods. A public official guilty of accepting a bribe is sentenced with a minimum of one-year imprisonment, while a private person trying to bribe faces a maximum of five-year imprisonment sentence. Article 62 of the UAE Constitution moreover addresses the issue of conflict of interests of government ministers by prohibiting them from practising any financial, professional or commercial occupation. Access the Lexadin World Law Guide or Ministry of Justice Legislations Portal for a collection of legislation in the UAE.

Government Strategies: UAE is part of the Arab Anti-Corruption & Integrity Network (ACINET), the regional anti-corruption network founded in 2008. The ACINET offers the anti-corruption commissions of several other Arab countries a permanent forum for exchanging expertise and experiences in the fight against corruption. The ACINET is also supported by a network composed of parliamentarians and representatives of non-governmental actors including civil society organizations and the private sector.

Anti-Corruption Agency: The UNDP Programme of Governance in the Arab Region reports that the Defence Ministry houses an anti-corruption unit and similar specialised units exist in police departments as well.

Anti-Money Laundering and Suspicious Cases Unit (AMLSCU): The UAE Central Bank's AMLSCU performs the functions of a financial intelligence unit (FIU) and is a member of the Egmont Group, the international network of financial intelligence units. According to the UNDP Programme of Governance in the Arab Region, the Central Bank has been charged with anti-money laundering tasks since 2002, and has since then blacklisted nearly 30 bank accounts and detected and stopped several money laundering attempts. Since 2001, independent banks have had to report to the Central Bank any transaction exceeding USD 10,900.

State Audit Institution (SAI): The SAI is the federal audit authority. The SAI is guaranteed financial and functional independence by federal law and reports directly to the Federal National Council. The SAI is charged with overseeing that the public funds have been allocated to a legal aim through the right procedure. However, the SAI is moving towards a model of auditing that not only controls that all legal requirements for spending have been observed, but also controls whether the state budget is managed efficiently and spent effectively. When cases of financial misconduct are detected, the President decides whether to prosecute the case before a special disciplinary council or to refer it to the concerned authority. The SAI publishes annual reports.

Ombudsman: The UAE does not have an Ombudsman organisation, but in 2006 the Human Rights Association (HRA) was established by ministerial decree as an independent body. Many of the received complaints are filed by detainees. The Bertelsmann Foundation 2010 states that the HRA has carved out a role for itself, however, its impact on government policies is negligible as the government still arrests people who express views considered to be an internal security risk.

E-Governance: The UAE government uses e-governance to provide more efficient and faster services and to improve citizens' satisfaction with government services. As an example, the mobile mPay system from 2008 can be used to pay government fees, and is scheduled to allow more services in the future. In March 2009, an e-government office was established to provide guidance for improving the online delivery of government services at all government levels. The Abu Dhabi government is also planning awareness campaigns to enhance the number of citizens' online payments to the government and the use of e-government services altogether. Most branches of government have websites containing information about their mandate and the service provided. Click here to access the UAE government website. The UAEinteract portal run by the National Media Council is a good starting point for gathering information about the UAE and the Ministry of Economy's website contains useful information for companies planning to invest in the country.

Public Procurement: The US Department of State 2011 reports that government tendering is not conducted according to generally accepted international standards, and re-tendering is the norm. However, public procurement does not seem to be a problematic area, as no reports on corrupt practices in relation to the awarding of government contracts are registered. The MENA-OECD Investment Programme 2006 reports that the role of intermediaries in the UAE is kept under control in relation to government contracting. Agents and intermediaries have to be registered, and their wages and rendered services have to be duly disclosed.

Whistle-Blowing: There appears to be no legislation encouraging witnesses of acts of corruption to come forward with a complaint. No whistle-blower hotlines are established nor any protection provided under the anti-corruption legislation. A 2009 private sector study reveals that some very large private companies have no internal whistle-blowing mechanisms and that workers might have no interest in reporting corporate malpractice as they usually work on a contract basis and therefore have a low degree of loyalty to their company.

General Comments on the Public Anti-Corruption Initiatives: Many articles and reports praise the efforts of the government in curbing corruption and enhancing accountability. Without doubt there is a shared perception that anti-corruption and anti-fraud legislation is enforced, thus providing a strong deterrent to future illegal acts. The wide display of e-governance is commendable, as it diminishes possibilities of face-to-face encounters that can result in bribes being exchanged. However, recent high profile scandals highlight the fact that legislation and controls have to be strengthened to avoid embezzlement and corporate fraud. Accounting practices need consequently to be strengthened and the lack of legislation requiring asset disclosure of employees of public and publicly owned enterprises addressed. The paucity of reports on the issue of corruption is also worrying, as it contributes negatively to governments' efforts to change UAE's reputation of opacity.