Susana Sierra, Executive Director of BH Compliance, spoke with attorney Jaime Lorenzini, Partner of Lorenzini-Twyman, and Carlos Andonaegui Elton, Retail Legal Manager of Banco BCI, who shared the company’s experience in implementing these models.
Jaime explained what a consumer protection compliance plan consists of, considering the particularity of its risk matrix, protocol, manual and trainings. “Behind any plan is the central notion of ‘risk of non-compliance’ with the norm, in this case the consumer protection law. It is not enough to put nice ideas on paper to approach compliance. You have to be astutely attentive to develop it correctly,” he said.
Carlos, on the other hand, based on the progress made in this area at BCI, pointed out that the compliance plan has to be based on the company’s DNA, which is represented, for example, in its purpose and values. She also said that flexibility and permanent internal adaptation are challenges inherent to this management.
Meanwhile, Susana made an analysis between compliance in consumer rights protection and the law of criminal liability of legal persons, determining several similarities in the compliance plans that an organization can develop and implement. He indicated that depending on the nature of the company, both issues can be integrated.
The 3 speakers agreed on the relevance of a compliance-oriented organizational culture in the prevention of crimes and the protection of consumer rights, coupled with the commitment of senior management.
December 10, 2020