Implementing Effective Integrity Programmes in Argentine Financial Services Providers (FSPs)
The Argentine Financial Services Providers (FSPs) sector faces significant challenges in implementing effective integrity programmes. Despite the enactment of the Corporate Criminal Liability Act and the Guidelines, FSPs struggle to adapt their programmes to local realities and address specific risks.
Key Challenges Facing FSPs
Some key issues include:
- Inadequate ethics codes: Ethics codes adopted by holding companies may not be suitable for all subsidiaries, leading to ineffective or inadequate programmes.
- Lack of attention to integrity in public tenders: FSPs often neglect rules and procedures to prevent corruption during bids, tenders, and interactions with the public sector.
- Insufficient training on Anti-Bribery and Corruption (ABC) measures: Training on ABC issues is often focused on foreign legislation, leaving local realities and circumstances unaddressed.
- Dispersion of business and management: FSPs with a large presence in various territories may struggle to ensure consistent training and awareness among employees and officers at distant branches and offices.
Addressing the Challenges
To address these challenges, FSPs should prioritize:
- Developing a comprehensive ethics code that addresses local realities and risks.
- Implementing effective procedures for integrity in public tenders, including record-keeping and avoiding informal communications.
- Providing training on ABC measures tailored to local legislation and circumstances.
- Ensuring consistent training and awareness among employees and officers across the organization.
- Conducting periodic risk assessments to adjust the programme’s effectiveness to changing business and regulatory environments.
- Demonstrating visible and unequivocal commitment from top management to the integrity programme.
Strengthening Integrity Programmes in FSPs
By addressing these areas, FSPs can strengthen their integrity programmes and better navigate the complexities of their operations in Argentina. A well-designed integrity programme is crucial for maintaining a positive reputation, ensuring compliance with regulations, and protecting against financial losses due to corruption.