Costa Rica: New regulation rules the adoption of anti-corruption and anti-bribery programs



On August 27, 2020, the regulation to the Law for Criminal Liability of Legal Entities on Domestic Bribery, Transnational Bribery, and other Crimes, Law No. 9699, was published by executive decree No. 42399-MEIC-MJP, one year after the entry into force of this law. The regulation aims to promote the establishment of the "Optional model for the organization, crime prevention, management, and control" (hereinafter "Model") and offer the regulatory framework for its adoption, both in private companies and in public entities.

According to the Regulation, the adoption of the Model must contemplate an evaluation of the risks of committing criminal conduct, derived from the context in which the legal entity operates. Likewise, the legal entity must develop internal regulatory tools and internal control systems, which are easily disseminated within the organization and create channels through which suspicions about the possible commission of any of the crimes contemplated in the Law can be reported.

Additionally, it refers to the need to designate a person or entity, whether internal or external to the company, in charge of supervising the establishment, operation, and compliance of the Model.

Under Law No. 9699, the effective implementation of the Model, in addition to being good practice in the prevention of corruption, enables the reduction of eventual sanctions to be imposed by up to 40%.

Do not hesitate to contact our Department of Criminal Matters, Compliance, and Anti-Bribery to obtain more information about adopting an adequate compliance program and anti-corruption and anti-bribery policies.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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