Implementing an Integrity Programme in Financial Services Providers (FSPs) in Argentina
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Adaptation to Local Legislation
When designing and implementing an integrity programme in a Financial Services Provider (FSP) in Argentina, it is crucial to adapt the programme to comply with local legislation. Specifically, this includes:
- Corporate Criminal Liability Act: Ensure that your programme meets the requirements of this act, which sets out the framework for corporate criminal liability in Argentina.
- Guidelines: Familiarize yourself with the guidelines issued by relevant authorities, such as the Argentine Securities and Exchange Commission (SEC), to ensure compliance with regulatory expectations.
Training of Directors, Administrators, and Employees
Creating a culture of integrity within an organization requires regular training for all stakeholders. This includes:
- Directors: Ensure that directors are aware of their responsibilities in promoting a culture of integrity and are trained on the programme’s objectives and requirements.
- Administrators: Provide administrators with the necessary training to effectively implement and maintain the programme.
- Employees: Regularly train employees on the programme’s components, including policies, procedures, and expectations.
Third-Party Due Diligence
Conducting thorough due diligence on third parties, business associates, and intermediaries is essential before contacting them or during the business relationship. This includes:
- Background checks: Verify the credentials and reputation of third-party service providers.
- Financial assessments: Evaluate the financial stability and soundness of third-party service providers.
Periodic Risk Assessment
A periodic risk assessment ensures that your integrity programme remains adequate in a rapidly evolving financial landscape. This includes:
- Regular reviews: Schedule regular reviews to assess the effectiveness of your programme.
- Stakeholder feedback: Gather feedback from stakeholders, including employees, directors, and third-party service providers.
Tone from the Top
Top management’s commitment to the integrity programme should be visible and unequivocal. This sets a clear tone for the organization and includes:
- Leadership involvement: Ensure that top management is actively involved in promoting a culture of integrity.
- Clear expectations: Communicate clear expectations for behaviour and performance.
By following these considerations, FSPs operating in Argentina can design and implement effective integrity programmes that comply with local legislation and promote a culture of integrity within their organizations.