Private-Sector Bribery in Saudi Arabia: Article 9 bis (1), Penalty and Company Duties

A procurement officer asking a supplier for a kickback, or a company paying an employee of its client to be preferred? Private-sector bribery became a crime in Saudi Arabia when the Anti-Bribery Law was amended to add Article 9 bis (1). Here is what it covers, the penalty, when a company employee is treated as a public official with a heavier penalty, and what companies should do.

Reviewed by: Ahmed Hasan AlShehriAttorney at USUS Law FirmLast updated: 28 October 2026

When is a company employee treated as a public official?

Article 8 defines "public official" widely: it includes employees of companies running a public utility or providing a public service, joint stock companies in which the government holds shares, banks and their board members, and public-benefit associations. A bank or electricity-company employee, for example, is treated as a public official under this law.

What companies should do

• A written gifts, hospitality and commissions policy.
• Documented dealings with suppliers and intermediaries, and review of unexplained commissions.
• A safe internal reporting channel and staff training.
• Anti-bribery clauses in supplier contracts.

Frequently asked questions

Is private-sector bribery a crime in Saudi Arabia?

Yes. Article 9 bis (1) of the Anti-Bribery Law punishes bribing employees of private companies, establishments, associations and professional bodies to breach their duties.

What is the penalty?

Up to five years' prison and a fine of up to SAR 500,000, or either; up to ten years and SAR 1 million where the entity is treated as a public one, such as a bank.

Usus Law Firm handles bribery cases and drafts compliance policies. See our governance charters and policies and criminal lawyer in Riyadh.

This article is general legal information and is not a substitute for advice on your specific case. Court proceedings in Saudi Arabia are in Arabic; the official Arabic text of each law prevails.