Article 19 of the Saudi Anti-Bribery Law

This article shifts responsibility from individuals to the commercial entity itself, so the penalty is not limited to the employee or manager who committed the offense.

To whom does it apply? To any private company or establishment, national or foreign, under two conditions:

• Its manager or one of its staff was convicted of an offense provided in the Law.
• It is established that the offense was committed in its interest.

The penalties the competent body must impose:

1. A fine not exceeding ten times the value of the bribe; or
2. Disqualification from entering into contracts with ministries, government departments or bodies with public legal personality to secure their purchases and carry out their projects and works; or
3. Both penalties.

The phrase "the competent body must impose" indicates that a judgment of one of these penalties or both is required once the two conditions are met, with the body assessing the appropriate penalty among them.

Reconsidering the disqualification: the Council of Ministers may reconsider the disqualification penalty after at least five years from the issuance of the judgment.

Article 20 supplements this provision: if the company is sentenced to disqualification, the government bodies that contract with it submit to the Council of Ministers what they consider appropriate regarding the works the company carries out, even if those bodies have no connection with the offense.

Companies that deal with government bodies should consult a lawyer specializing in criminal matters or a company law lawyer at any suspicion.