Financial Crime World

Implementing Integrity Programmes in Financial and Securities Institutions in Argentina

Introduction

The Argentine Financial and Securities Code (CSAF) requires financial and securities institutions (FSPs) to implement an integrity programme that includes anti-bribery and corruption (ABC) measures. This code aims to prevent bribery, corruption, and other illicit activities within the sector.

Adapting ABC Programmes to Local Reality

FSPs operating in Argentina must adapt their ABC programmes to the local reality and circumstances, rather than relying solely on foreign legislation such as the US Foreign Corrupt Practices Act (FCPA). This ensures that the programme is tailored to meet the specific needs of the institution and the country.

Key Components of an Integrity Programme

An effective integrity programme for FSPs in Argentina should include:

Anti-Bribery and Corruption Measures

  • Implementing policies and procedures to prevent bribery and corruption
  • Establishing a culture of integrity within the institution

Integrity in Public Tenders and Interactions with the Public Sector

  • Prioritising integrity in public tenders and interactions with the public sector
  • Ensuring compliance with regulations when dealing with state-owned companies, payroll services for state agencies, and the issuance of public debt bonds

Training of Directors, Administrators, and Employees

  • Providing training tailored to the needs and characteristics of individuals involved
  • Adapting training specifically to local legislation and circumstances

Third-Party Due Diligence

  • Assessing the integrity and trajectory of third parties before establishing a relationship with them

Periodic Risk Assessment

  • Conducting regular risk assessments to address new technologies, regulations, and potential risks

Tone from the Top

  • Ensuring that top management is committed to the integrity programme
  • Maintaining clear written records of interactions or avoidance of interactions with high-level public officers

Conclusion

An effective integrity programme for FSPs in Argentina must include ABC measures, training, third-party due diligence, periodic risk assessment, and tone from the top, all tailored to local legislation and circumstances. By implementing these components, FSPs can ensure compliance with laws and regulations, promote a culture of integrity within the institution, and prevent bribery, corruption, and other illicit activities.

References

  • Argentine Financial and Securities Code (CSAF)
  • Corporate Criminal Liability Act
  • Guidelines for Implementing Integrity Programmes in Financial and Securities Institutions in Argentina

Note: The above article is written in markdown format with proper headings, subheadings, and bullet points. It follows the structure of the original text while making it more readable and accessible.