While the Argentine business community is no stranger to transnational corruption investigations, the companies historically involved in those investigations have been local subsidiaries of major U.S. or European corporations (IBM and Siemens are the most prominent examples). As a result of such investigations, local subsidiaries of foreign companies have dutifully implemented their global compliance programs in their Argentine operations in much the same way they do in other jurisdictions around the world. By comparison, local Argentine companies, even those with substantial international operations and varying levels of connectivity to the U.S. or European markets, have paid relatively little attention to the development of compliance programs. However, recent events both within and outside of Argentina have started to change this approach as a small but growing number of Argentine companies have begun to realize that the implementation of a robust corporate compliance program is a business imperative for companies that wish to compete in the global marketplace.
In this client alert, RK&O partners Jeffrey A. Lehtman and David B. Massey explore the driving forces behind the Argentine compliance revolution and how companies should prepare by establishing a compliance framework.