Under the leadership of its CEO, Paul Keary, Teneo has played a pivotal role in shaping a misleading public narrative about its Saudi Arabian government clients, including the entity building NEOM and the Saudi government Public Investment Fund, omitting material information about human rights abuses associated with these entities and sanitizing the Saudi government's image.
Teneo, a global consulting and advisory firm, has contributed to and benefited from human rights abuses in Saudi Arabia, in breach of its obligations under the United Nations Guiding Principles on Business and Human Rights. It has worked as a foreign agent for Saudi Arabia's government agencies, including preparing and distributing promotional material designed to polish the government's image and secure investor confidence, while failing to disclose material information about its actual record of abuse and crimes and misleading investors and the public with incomplete information about its Saudi government clients and the risks of doing business with them.
One of Teneo's major clients is NEOM, a $500 billion government-owned infrastructure agency, whose project to build a megacity in northwest Saudi Arabia has been rife with human rights abuses. Teneo is responsible for producing NEOM's communications in order to attract investors but has failed to disclose the abuses and risks associated with the project, including the forcible displacement of the indigenous population residing there and abuses of migrant worker rights.
Teneo is also registered as a foreign agent for Saudi Arabia's Public Investment Fund (PIF) and has submitted copies of its contracts with the PIF to the Foreign Agents Registration Act (FARA) unit of the U.S. Department of Justice. Teneo's contract with the PIF requires Teneo to secure investor confidence and promote a positive image to the public. Teneo has misled the public and investors by omitting material facts about serious human rights violations in which the PIF has been implicated, and has also failed to disclose the human rights risks and national security concerns raised by PIF's influence campaign and acquisitions in the U.S. By failing to disclose these violations and presenting the PIF as a legitimate global investment partner without addressing its involvement in human rights abuses, Teneo has effectively provided an inaccurate, misleading and sanitized narrative that obscures the risks of engaging with the PIF.
Finally, Teneo has betrayed its responsibilities to the American people by failing to comply with a subpoena from the Senate Permanent Subcommittee on Investigations' hearings into the national security risks of the Saudi government's acquisitions and investments in the U.S., failing to testify about its activities for its Saudi client, the PIF.
Human Rights Abuses Associated with NEOM
NEOM is envisioned as part of Crown Prince Mohammed bin Salman's Vision 2030 to transform Saudi Arabia's Red Sea coast into a "futuristic urban area" powered by renewable energy and advanced technology. However, the project has been marred by significant controversies and human rights abuses, including the forced displacement of local communities like the Huwaitat tribe, whose resistance has been met with government violence and repression, and the abuse of migrant workers. Whether considering state-sponsored forcible evictions, spying and surveillance tactics employed to intimidate, or Saudi Arabia's history of labor rights abuses, various human rights abuses are associated with NEOM.
NEOM makes a series of commitments relating to its human rights obligations, stating that "we believe in the importance of respecting human rights, as a fundamental aspect of our mission to become an 'accelerator of human progress.'" However, there is no indication that NEOM has taken meaningful steps to abide by these commitments, given the systemic abuse of migrant workers in Saudi Arabia, including those employed to build NEOM, as well as the forced displacement of the indigenous population on the territory of the future NEOM site.
NEOM has created a toxic, harmful work environment for its employees, with NEOM executives making racist and misogynist remarks, including Wayne Borg calling migrant workers "f—ing morons" and saying "that is why white people are at the top of the pecking order," following the death of three workers at the site.
The forcible displacement of the indigenous population have been the most prominent abuses associated with NEOM. In March 2020, Saudi security forces initiated a campaign to forcibly evict residents from the region designated for NEOM. This campaign included a series of raids on homes, resulting in the arrest of at least 20 individuals who refused to leave. The most egregious incident occurred on April 13, 2020, when Saudi security forces armed with heavy weapons surrounded the home of Abdul Rahim al-Huwaiti, a prominent local figure who openly opposed the evictions and refused to leave his property. During the raid, Saudi forces killed al-Huwaiti, an act widely condemned as an excessive and unjust use of force.
The Saudi government has also been criticized for its inadequate compensation to those evicted. The displaced individuals, mainly from the Huwaitat tribe, received unfair compensation packages, and many were detained when they protested their mistreatment. Reports find that government security forces arrested at least 47 tribe members in connection with the NEOM project. Subsequently, Saudi courts sentenced three to death, and handed at least 15 others lengthy prison terms ranging from 15 to 50 years.
The crackdown on dissent to the displacement and abuse associated with NEOM extends beyond physical force. Saudi authorities have employed intimidation tactics to suppress any opposition to NEOM. These tactics include surveillance measures being built in NEOM that raise major privacy concerns. NEOM is also reported to be using data services and surveillance technology from China, which analysts say may be used as part of a mass surveillance program. Coupled with the city's design of unprecedented government monitoring of, and data collection from, residents and workers, these can be severe infringements on privacy rights.
NEOM has been implicated in other human rights abuses, including labor rights abuses involving migrant workers. Migrant workers involved in the construction of Saudi Arabia's NEOM megaproject face significant exploitation and abuse, rooted primarily in the kafala system, which severely limits their autonomy by granting employers control over their employment and legal status. In Saudi Arabia, these workers often endure poor living conditions, including exposure to extreme heat without adequate safety measures, contributing to multiple worker deaths on the site. Additionally, many workers experience wage theft and delayed payments, exacerbating their vulnerability. The risk of injury or death due to unsafe working conditions is high, and reports indicate that fatalities among migrant workers in Saudi Arabia are often underreported, further obscuring the scale of abuse.The construction projects in NEOM rely on these vulnerable migrant laborers who face exploitation and harsh working conditions. Investigations have also revealed a harmful work environment for NEOM employees, including verbal abuse, misogyny and racism by senior executives.
While specific evidence of abuses of NEOM construction workers is scarce due to the project's recent launch, historical patterns in Saudi Arabia's treatment of migrant workers raise significant concerns. Early reports noting the death of three workers, and concerns about unsafe conditions and inadequate labor protections have already surfaced. Further reports of abuse appear in an upcoming undercover film, while journalists uncover additional concerns associated with the project such as issues relating to environmental sustainability. Given the size of the project and Saudi Arabia's laws stripping migrant workers of their most basic rights, migrant workers at NEOM are likely to face the abuse and exploitation faced by migrant workers throughout the country.
Human Rights Abuses Associated with the PIF
The PIF, chaired by MBS, has been implicated in numerous human rights abuses and financial misconduct, serving as a tool for consolidating political power and evading accountability. MBS has used the PIF to pursue crimes, including in connection to the murder of Washington Post columnist Jamal Khashoggi, and to acquire assets illegally confiscated from citizens of Saudi Arabia. In its report, the U.S. Office of the Director of National Intelligence (ODNI) concluded that MBS ordered the murder of Khashoggi. One of the Crown Prince's close aides, Mohammed al-Sheikh, ordered the PIF governor, Yasir al-Rumayyan, to transfer at least 20 companies illegally confiscated from Saudi businessmen in 2017 to the PIF's ownership. Among them was Sky Prime Aviation, which owned the two jets that carried Saudi government agents to Istanbul to murder Khashoggi in October 2018.
Saudi security forces under orders from MBS confiscated these companies and their assets, including the two jets, as part of the infamous "anti-corruption" campaign that MBS launched, leading to the extra-judicial arrests, torture, and shakedown of around 400 Saudi businesspersons and princes. At least one died because of the torture and many were detained. As a result of these shocking crimes and abuses, global investor confidence in Saudi Arabia dramatically declined, and many investors either refused to do business with the Kingdom and its PIF, or withdrew their own investments in the country.
In addition, the U.S. Congress and American analysts have raised extensive concerns about human rights and national security around the PIF's problematic government influence campaign and extensive acquisitions of a vast swath of American assets. The PIF has used its extensive wealth to make "investments" in the newly-established companies of former government officials just weeks after they left office, despite the absence of any financial return, and indirectly made payments to other government officials in the form of fees to their companies, consultancy contracts, and other business ties. The PIF's investments in Jared Kushner and Stephen Mnuchin's investment firms, its purchase of LIV golf, and payments to former President Donald Trump all present concerns around foreign influence in the U.S. In the case of the PIF's attempted acquisition of PGA Tours, this reportedly included problematic speech restrictions on staff, players and associates of PGA Tours. As detailed below, these acquisitions have invited Federal government scrutiny and investigation.
Teneo's Work in Saudi Arabia
Teneo works for the Saudi government as a foreign agent providing services, including public relations consultations for NEOM and crisis management for the PIF.
- Teneo's Work for NEOM: Since August 2021, Teneo has signed multiple contracts with NEOM for fees of $275,000 a month. Under the terms of the contracts, Teneo is tasked with developing a comprehensive communications strategy to promote NEOM and its various sectors, departments and regions. This strategy includes providing strategic counsel, media relations, crisis management, thought leadership initiatives, and content creation services. The contracts also specify that Teneo will serve as an extension of NEOM's communications team, with senior staff dedicating significant time on-site at NEOM.
Teneo's most recent contract, expanding upon its previous agreement, started on September 1, 2023. It includes services such as strategic communications counsel, day-to-day communications support, messaging and narrative development, external communications management, media training, and crisis support services. The contract also covers reviewing and assessing speaking opportunities for NEOM spokespeople at conferences and events. Under the terms of this contract, which expires on November 30, 2024, Teneo has the option to extend the agreement for an additional 12 months. - Teneo's Work for PIF: Saudi Arabia's PIF, with assets in excess of $925 billion, has invested over $31 billion in 2023 alone. MBS, as chairman and de facto decision-maker of the PIF, exercises extensive control over the fund's decisions. This was evident in 2022 when the PIF invested $2 billion in Jared Kushner's private equity firm, Affinity Partners, despite objections from the fund's advisory panel. The panel raised concerns about Kushner's inexperience, the risks involved, and the potential for negative public relations, but MBS overruled these objections, pushing the investment forward.
Teneo is registered as a foreign agent for the PIF and has filed copies of its contracts with FARA. Teneo's responsibilities, outlined in its contracts, include positioning the PIF as a sophisticated global investment organization and managing crisis responses and media relations. In one contract, with an estimated timeline of June 3, 2023 to January 4, 2024, the total value of fees is listed at $2.190 million. The contract provides:
[Teneo] is providing the foreign principal with stakeholder communications advice and support related to its sports investment strategy. In providing these services, the registrant may engage in communications with members of the U.S. media on behalf of the foreign principal and may support or participate in government affairs engagement in the United States.
Other contracts between Teneo and the PIF list capped fees for a 12 month period at $4.305 million to provide services for "engag[ing] in communications with members of the U.S. media on behalf of the foreign principal and may support or participate in government affairs." There are also renewal agreements for contracts between Teneo and the PIF that extend the original agreements to at least one additional year, to December 31, 2024. These agreements explicitly list Teneo's role of "providing strategic consulting and communications advisory services."
Breach of United Nations Guiding Principles on Business and Human Rights and OECD Recommendations
Under the United Nations Guiding Principles on Business and Human Rights (the "Guiding Principles"), businesses have a responsibility to "avoid causing or contributing to adverse human rights impacts through their own activities" as well as "to prevent or mitigate adverse human rights impacts that are directly linked to their operations, products or services by their business relationships, even if they have not contributed to those impacts." Working to promote a positive image of governments, agencies, government investment funds, or officials like those in Saudi Arabia responsible for human rights abuses, while omitting material, comprehensive information, contributes to such abuses.
The Organisation for Economic Co-operation and Development (OECD) similarly has established Guidelines for Multinational Enterprises (MNEs), which set forth recommendations to encourage responsible business conduct across various sectors. These guidelines focus on transparency, stakeholder engagement, and the avoidance of harm, especially regarding human rights, labor rights, and environmental sustainability. For companies operating in complex international environments, these principles emphasize the need for due diligence, responsible corporate governance, and accountability in all business operations.
The OECD's recommendations to multinational enterprises, including firms like Teneo, fall under several key areas:
- Human Rights Due Diligence: The OECD guidelines emphasize that companies must conduct thorough due diligence to identify, prevent, and address any actual or potential adverse human rights impacts. This means that businesses should not only assess their own operations but also scrutinize their business partners, supply chains, and clients for potential human rights risks. If such risks or abuses are found, the company must take action to mitigate them, whether by altering business relationships or ending them if necessary. We are unaware of any due diligence conducted by Teneo to assess the human rights impacts of its work for Saudi government entities.
- Transparency and Disclosure: The OECD guidelines call for full transparency regarding business activities, particularly where there are risks to human rights or other adverse impacts. Companies are expected to provide clear, accurate, and complete information to stakeholders, including the public, governments, and investors. This includes disclosing any material information that could affect human rights, environmental sustainability, or economic stability. Selectively presenting positive information while omitting risks or abuses, as Teneo has done with its promotional materials for NEOM and PIF, directly contravenes this recommendation.
- Stakeholder Engagement: Engaging with affected communities and stakeholders is a critical component of the OECD guidelines. Companies should involve those impacted by their operations in meaningful dialogue and decision-making processes. This includes consulting with local populations, employees, and civil society organizations, especially when projects may lead to displacement, environmental harm, or labor exploitation. In the case of NEOM, the lack of engagement with the indigenous Huwaitat tribe, who were forcibly displaced, highlights a violation of this OECD recommendation. We are unaware of any stakeholder engagement undertaken by Teneo in connection with its work for Saudi government entities.
- Avoiding Complicity in Human Rights Violations: The OECD guidelines recommend that companies avoid being complicit in human rights abuses, even indirectly. If a company's business relationships or services are contributing to or benefiting from abuses, the company is obligated to take steps to address these impacts. This might involve ending contracts with abusive clients or changing practices to prevent further harm. In the case of Teneo, its work for both NEOM and PIF appears to ignore these obligations, as the firm continues to benefit from projects linked to documented human rights abuses.
- Remediation: When a company is found to be linked to adverse impacts, the OECD calls for businesses to cooperate in providing or facilitating remedies to those harmed. This can include compensation, public acknowledgment of wrongdoing, or measures to restore affected communities. So far, there has been no indication that Teneo has engaged in any remediation efforts for the human rights abuses linked to its Saudi clients.
Given the well-documented human rights abuses associated with the PIF and NEOM, including the forcible displacement of indigenous communities and exploitation of migrant workers, Teneo's failure to disclose these risks in its promotional materials for contracts with both clients raise serious concerns regarding its compliance with OECD principles. By sanitizing the narrative around the PIF and NEOM's development, Teneo not only misleads stakeholders but also undermines the integrity of its own operations. The OECD Guidelines call for full disclosure of material information that could impact human rights, making Teneo's omission of these details an apparent violation of its responsibilities under these international standards.
This selective disclosure not only runs counter to the transparency and stakeholder engagement called for by the Guiding Principles, but also raises questions about Teneo's commitment to human rights due diligence in its client engagements.
Promotional Materials for NEOM and PIF Omit Accurate and Complete Information About Human Rights Abuses
- The promotional materials for NEOM, produced and disseminated by Teneo focusing solely on the purported benefits of NEOM are highly problematic due to their omission of material information about the project. These materials also provide public relations cover for the project, violating the Guiding Principles by failing to disclose the serious human rights abuses associated with the project. This serves to mislead the public and the investor community about NEOM's ongoing record of abuses and risks for future violence, instability and abuse, including the forced displacement of local communities and the use of violence against those who resist including the human rights abuses associated with it. Specifically, the materials paint a glossy, misleading picture of innovation, luxury, and sustainability while ignoring the abuses associated with the development, such as abuse of migrant workers and confiscation of private property, generating additional revenues for the project.
A Teneo press release about Elanan, a new wellness retreat in NEOM, describes it as a place where guests can "soak up the spectacular views" and experience "ultra-modern design techniques that blend with nature." This description attempts to present NEOM as a model of sustainable development in harmony with nature but fails to mention the forced evictions and violent suppression of local communities, such as the Huwaitat tribe, who have been displaced to make way for these developments.
The Teneo materials promoting other NEOM projects, like Xaynor, Siranna, and Aquellum, which are luxury developments offering elite private clubs, high-end tourism destinations, and futuristic lifestyle communities, also focus on their innovative and luxurious features. While promoting NEOM's image of sustainability, luxury and cutting-edge technology to attract investors and public support, this narrative omits any reference to the social and human rights costs abuses associated with the construction and maintenance of NEOM, as well as the extensive surveillance and monitoring to which any residents in NEOM will be subject. The materials also exclude any reference to the abuse of migrant workers at NEOM, who are subject to deprivation of basic labor rights in the Kingdom.
This selective presentation provides a sanitized view of NEOM, effectively acting as propaganda that misleads the public, including consumers and investors, by omitting material information about the human rights abuses associated with NEOM's construction and the risks to stability and security that these abuses pose. This approach not only breaches ethical and legal standards that mandate providing complete and accurate information about a project to consumers and investors, but also raises significant concerns about the transparency and accountability of Teneo in promoting NEOM.
- The promotional materials for the PIF, produced and disseminated by Teneo are also highly problematic because they contribute to and benefit from the government's human rights abuses. Teneo's communications and promotional materials about the PIF seek to promote the PIF and Saudi government's interests to "increase the nation's attractiveness" to investors and the public, ostensibly representing the PIF's innovation, technological advancement, positive transformation, and public entertainment, but completely omit any disclosure of material information about the PIF's role in human rights abuses, as well as the national security risks and malign political influence of the PIF. Teneo's public relations materials for the government's fund boast that it is "one of the largest and most impactful sovereign wealth funds in the world," omitting information about the unlawful means through which it has acquired its funds by arbitrarily and violently stripping assets from Saudi citizens.
Teneo's Failure to Comply with Senate Subpoena
In 2023, the Senate Permanent Subcommittee on Investigations (PSI) launched an inquiry and hearings into the activities of U.S.-based consulting firms working with the PIF, as part of a broader effort to investigate the extent and national security implications of the Saudi government's foreign influence within the U.S., particularly focusing on the PIF's strategic investments in high-profile sectors such as professional golf. The Subcommittee's probe intensified following the announcement of a merger between the PGA Tour and LIV Golf, an entity owned and controlled by the PIF, underscoring the PIF's potential influence in shaping U.S. cultural and economic landscapes. DAWN had urged the Senate to investigate the national security risks of Saudi Arabia's investments and acquisitions in the United States, and documented the payments made by the PIF and its subsidiaries, such as LIV Golf, to U.S. government officials.
In August 2023, the PSI requested documents and information from Teneo regarding its role in the PIF's attempted takeover of PGA Tour as part of its investigation. The PSI sought details about the meetings of one of Teneo's consultants, Stephen Cohen, with the PIF and PGA Tour immediately prior to the merger's announcement. The PSI also sought information from McKinsey & Company, M. Klein & Co., and Boston Consulting Group. The firms did not comply with the requests, so the PSI issued a subpoena for all of the firms on November 2, 2023.
In an unprecedented development that highlights the intensifying clash between U.S. Congressional authority and foreign influence, on November 30, 2023, the PIF filed a lawsuit against Teneo and the other consultants in a Saudi court, seeking to block them from providing any documents to the Senate Subcommittee. A Saudi court issued a temporary injunction, apparently prohibiting Teneo and the other firms' disclosure of materials requested by Congress. The firms claim that if they were to comply with the subpoena, their staff may face criminal liability under Saudi law. Teneo further claimed that the Saudi Penal Law on Dissemination and Disclosure of Classified Information and Documents prevents it from cooperating with the Senate subpoena, and that the Saudi government had threatened to subject Teneo to "severe criminal liability" for cooperating with the subpoena. Teneo further cited two articles in the law stipulating a punishment of "imprisonment for a term not exceeding twenty years or a fine not exceeding one million Saudi Riyals, or both."
Although Teneo officials said that they would comply with the subpoena, to date they have not. Teneo, and other firms' failure to adequately provide the requested information, citing pressure and threats from its Saudi government client as an excuse, constitutes a significant challenge to the authority and oversight function of the U.S. legislative and judicial branches. It sets a perilous precedent that, if allowed to stand, could enable foreign governments to impede Congressional investigations and evade accountability in the U.S. simply by invoking the primacy of their own laws and courts. This would severely undermine the ability of Congress to fulfill its constitutional mandate to conduct oversight, investigate wrongdoing, and legislate solutions.
After the Saudi court's injunction, Teneo and other consulting firms failed to comply with Congressional subpoenas. In a Senate hearing held on February 6, 2024, Senator Maggie Hassan addressed this issue directly, highlighting that the firms were "citing an injunction from a Saudi Arabian administrative court, a court that is notoriously not independent and under the direct influence of the Saudi regime." She further criticized the actions of the firms, stating: "By refusing to respond to this Committee's subpoena and request for a legal justification for your refusal, your firms appear to have placed your loyalties to Saudi Arabia above your loyalty to the United States of America, our national security, and the principles of transparency." Paul Keary, co-founder and CEO of Teneo, represented the firm at the hearing and responded to questions about its work for the Saudi government and its failure to comply with the Senate subpoena.
As of October 2024, there have been no further public developments in this standoff between the Senate Subcommittee and the consulting firms, including Teneo. Teneo continues to maintain its position to defend its failure to comply with the subpoenas, citing the Saudi court injunction, although it has also said it will comply with the subpoena, without indicating when it will comply. The Senate has not taken any additional actions to enforce the subpoenas, and the matter appears to have faded from public attention. This unresolved situation leaves significant questions about the extent of foreign influence on U.S. businesses and the ability of Congress to conduct oversight when faced with resistance from foreign governments.
DAWN's Recommendations:
In its communications and strategic advisory work for NEOM and the PIF, Teneo appears to be in breach of its responsibilities under the Guiding Principles and the OECD Guidelines. By promoting sanitized, misleading and incomplete information about these Saudi government-controlled entities, with the specific intent of improving their image and wooing investors and consumers, while omitting material information about the well-documented human rights abuses associated with them, Teneo is effectively contributing to and providing cover for the Saudi government's abuses and its efforts to whitewash its record and evade accountability. This lack of transparency not only fails to prevent or mitigate the adverse human rights impacts to which Teneo is directly linked through its business relationships, but makes the firm complicit in obfuscating them from public scrutiny. Teneo's apparent prioritization of its lucrative contracts over human rights considerations is particularly egregious given the Saudi government's brazen attempt to block the firm from complying with a U.S. Senate subpoena—an unprecedented challenge to Congressional oversight that Teneo is enabling through its lack of cooperation.
As a firm that markets itself as helping clients navigate complex reputational challenges, Teneo should lead by example in upholding human rights standards, not contribute to efforts to minimize or conceal grave abuses. Therefore, DAWN calls on Teneo to commit to the following:
- Client Due Diligence: Teneo should conduct a thorough due diligence review examining the human rights and humanitarian law record of Saudi Arabia, NEOM, and the PIF. This review should determine the extent to which Teneo's representation contributes to, or benefits from, any of their human rights or humanitarian law abuses, including by misrepresenting or omitting information to the public or U.S. government officials about their human rights record. Teneo should make such reviews public.
- Engage with Stakeholders: Teneo should engage with affected communities and stakeholders impacted by their business for Saudi government entities in meaningful dialogue and decision-making processes. This includes consulting with local populations, employees, and civil society organizations, especially when projects may lead to displacement, environmental harm, or labor exploitation. Teneo should engage with the indigenous Huwaitat tribe, who have been forcibly displaced, as well as migrant workers involved in the construction of NEOM. It should also engage with civil society organizations defending the rights of people victimized by the PIF.
- Refuse to Work for Abusive Governments, Agencies, or Officials: Teneo should pledge to decline representation of Saudi Arabia, NEOM, and the PIF, given the credible information implicating them to human rights abuses.
- Adopt and Comply with the OECD Recommendations and the UN Guiding Principles: Teneo should adopt the OECD Recommendations, including those aiming to enhance transparency, honesty, and accuracy in the information provided to government officials about their Saudi clients. Teneo should also adopt and fully implement the UN Guiding Principles on Business and Human Rights in all its operations, particularly in relation to its work for Saudi entities.
- Assess Human Rights Impact of Lobbying Activities: Teneo should immediately assess its existing lobbying and public relations activities for NEOM and the PIF to evaluate whether they contribute to or benefit from adverse human rights impacts pursuant to the UN Guiding Principles. Where such contribution or benefit exists, Teneo should take appropriate measures to address them, including, when necessary, by terminating its existing contracts with these Saudi entities. This includes a responsibility to prevent or mitigate adverse human rights impacts that are directly linked to Teneo's activities, even if Teneo has not directly contributed to those impacts.
- Remedy Harms Caused by Adverse Impacts of Teneo's Business with Saudi Entities: Teneo should cooperate in providing or facilitating remedies to those harmed by its ongoing business relationships with NEOM and the PIF, including compensating those harmed, publicly acknowledging their wrongdoing, or taking measures to restore affected communities, such as the Huwaitat tribe.
- Comply with U.S. Senate Committee on Investigations Subpoena: Teneo should immediately comply with the subpoena issued by the Senate Permanent Subcommittee on Investigations, providing all requested documents and information regarding its work for the PIF, regardless of any injunctions from Saudi courts. Teneo should prioritize its obligations under U.S. law and its responsibility to cooperate with Congressional oversight over any threats of legal action from its foreign clients.
