A Brief Overview of Argentina’s Upcoming Integrity and Transparency Registry

On April 16, 2021, the Anti-corruption Office (the “OA,” after its acronym in Spanish) issued Resolution No. 3/2021 in which it entrusted the Transparency Policies Planning Directorate with the task of setting up an Integrity and Transparency Registry of Companies and Entities (the “RITE,” after its acronym in Spanish). The Registry will operate through a digital platform and its aim is to contribute to the development and improvement of integrity programs. The Registry will also promote the exchange of good practices and transparency in interactions within the private and public sectors.

The OA highlighted that the Registry “will collaborate with the effective implementation of Law No. 27,401 on Corporate Criminal Liability to improve compliance with statutory requirements for contracting with the Government and enhance public entity assessment of integrity programs.” The OA also stated that the Registry will serve as a source of public and complementary information on performing due diligence tasks in accordance with anti-money laundering and anti-terrorism financing regulations.

This initiative follows the recommendations of the OECD Integrity Review on Argentina conducted in 2019 and has the support of the Inter-American Development Bank.

In addition, the Resolution sets out to build bridges between public entities, companies, chambers, business actors and intermediate organizations so as to generate incentives for effective public policy implementation.

Thus, on April 27, the OA held a virtual meeting that brought together more than 270 local representatives linked to compliance and integrity programs, where it outlined the goals, progress and first steps in designing the RITE.

During the virtual meeting, the OA also presented its registry implementation work plan, which consists of the following stages:

• Registry design: consists of surveying and outlining local and international standards and good practices on corporate transparency and anti-corruption, defining key fields and alternatives in developing the platform and outlining its content.
• Key actor involvement: consists of coordinating meetings and seeking consensus with different organizations and key actors to develop the registry while identifying incentives to strengthen its adoption.
• Digital platform development: consists of pinpointing key aspects to cover in training activities, and self-diagnosis, developing mock-up and testing modules, and launching the platform.

Based on the information the OA has released so far, the intended practical and legal effects of RITE registration remain unclear.

We will have to wait and see how these regulations develop to know what their effects and consequences may be.