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Importance of an Integrity Program in Financial Services Providers

In Argentina, maintaining a culture of integrity is crucial for financial services providers (FSPs) to prevent corruption and ensure compliance with regulations. This article highlights several key aspects that FSPs should consider to maintain a strong integrity program.

Adaptation of Foreign ABC Legislation

While studying and using foreign legislation for technical purposes is acceptable, it’s essential to avoid simply adapting these laws without considering local realities. FSPs must take into account the specific needs and challenges of their business in Argentina.

• Consider the following:
  • Local regulations and laws
  • Cultural differences and nuances
  • Economic conditions and industry standards

Integrity in Public Tenders

FSPs should pay close attention to interactions with the public sector, including credit agreements, payroll services, and issuing public debt bonds. Informal communications and lack of procedures can lead to reputational risks.

• Key considerations:
  • Transparency and accountability
  • Clear communication channels
  • Established procedures for tendering

Training of Directors, Administrators, and Employees

Training should be prioritized based on risk and adapted to the needs of different personnel, including ABC measures distinct from AML (Anti-Money Laundering) training.

• Key considerations:
  • Risk-based approach
  • Adapted training for different roles
  • Continuous education and awareness

Third-Party Due Diligence

FSPs must conduct thorough due diligence on third parties, business associates, and intermediaries to ensure their integrity and trajectory.

• Key considerations:
  • Thorough research and investigation
  • Regular monitoring and updates
  • Clear policies and procedures

Periodic Risk Assessment

An adequate program should be adjusted to the company’s risks, dimension, and economic capacity, with periodic assessments to ensure its adequacy.

• Key considerations:
  • Ongoing risk assessment and analysis
  • Continuous improvement and adaptation
  • Effective communication and implementation

Tone from the Top

Top management must demonstrate visible and unequivocal commitment to the integrity program.

• Key considerations:
  • Leadership and accountability
  • Clear vision and messaging
  • Encouragement of a culture of integrity