Argentina continues to face structural barriers that limit the effective detection and enforcement of foreign bribery, according to the latest report on its implementation of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. In particular, the absence of a legal framework to protect whistleblowers remains a key gap in Argentina's detection system. While foreign bribery enforcement has progressed, cases continue to face delays, posing evidentiary and statute of limitations challenges. Very few cases advance to prosecution. No legal person has yet been investigated or sanctioned for foreign bribery under the Corporate Liability Law (CLL), eight years after its adoption.
The OECD Working Group on Bribery also welcomes positive developments, including Argentina's first concluded foreign bribery case against a natural person in 2025 and the detection of 17 new foreign bribery allegations since Argentina's Phase 3bis evaluation in 2017. Specialised bodies, such as PROCELAC (Special Prosecutorial Office for Economic Crimes and Money Laundering) and DAJUDECO (Directorate for Judicial Assistance in Complex Crimes and Organised Crime), have reinforced analytical capacity and supported more proactive approaches to transnational bribery cases, including through enhanced international co-operation and inter-agency co-ordination.
To improve effectiveness in preventing, detecting and enforcing the foreign bribery offence, the Working Group recommends that Argentina:
- Adopt, as a priority, a comprehensive whistleblower protection framework covering both the public and private sectors.
- Ensure that foreign bribery cases are advanced and brought to prosecutorial decision without undue delay.
- Fully implement across the few remaining federal jurisdictions the Federal Criminal Procedure Code (CPPF), which represents one of the most significant criminal justice reforms in recent decades.
- Substantially reduce the number of judicial vacancies and surrogate judges.
The OECD Working Group on Bribery in International Business Transactions comprises the 46 Parties to the Convention, including Argentina. Established in 1994, the Working Group is responsible for overseeing the implementation and enforcement of the OECD Anti-Bribery Convention, the OECD Anti-Bribery Recommendation, and associated instruments, using a robust peer-review monitoring mechanism.
