Financial Crime World

Implementing Integrity Programmes in Financial Services Providers: A Must for Anti-Bribery and Corruption Measures in Argentina

Introduction

In the context of anti-bribery and corruption (ABC) measures, implementing an integrity programme is crucial for financial services providers (FSPs) in Argentina. A well-designed programme can prevent and detect ABC issues, which can have severe consequences for FSPs, including reputational damage, loss of business, and even criminal liability.

Key Aspects of an Effective Integrity Programme

An effective integrity programme should include the following key aspects:

Training

  • The importance of training directors, administrators, and employees on ABC measures cannot be overstated.
  • Training should be adapted to their needs, characteristics, and the company’s operational capacity.

Third-Party Due Diligence

  • FSPs should conduct thorough due diligence on third parties, business associates, and intermediaries prior to engaging with them or during the business relationship.

Periodic Risk Assessment

  • A periodic risk assessment is essential to ensure the adequacy of the programme, particularly in an ever-evolving financial landscape.

Tone from the Top

  • The commitment of top management to the programme should be “visible and unequivocal,” as stated in the Corporate Criminal Liability Act and the Guidelines.

Challenges FSPs May Face in Argentina

Implementing an integrity programme can be challenging, especially in a local context. Some specific challenges FSPs may face include:

Local Reality

  • ABC training should be adapted to the local reality, including providing an adequate defense.
  • This requires an understanding of the cultural and operational nuances that can affect the programme’s effectiveness.

Fintechs

  • Financial business is constantly evolving, making periodic risk assessments necessary for fintechs and general FSPs.
  • This requires staying up-to-date with industry developments and regulatory changes.

Interactions with Public Sector

  • FSPs should give close attention to interactions with the public sector, recording every meeting and avoiding informal communications.
  • This is crucial in maintaining transparency and preventing potential ABC issues.

Conclusion

In conclusion, implementing an integrity programme is essential for FSPs in Argentina to prevent and detect ABC issues. By following key aspects such as training, third-party due diligence, periodic risk assessment, and tone from the top, FSPs can maintain a strong commitment to ABC measures. Additionally, understanding local challenges and staying adaptable can help FSPs navigate the complexities of implementing an integrity programme in Argentina.