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In brief

On 25 April 2022, the Anti-Corruption Office (OA) approved the System for Monitoring Private and Public Activities Before and After the Exercise of Public Function (MAPPAP), with the purpose of collating and verifying compliance with public ethics regulations of individuals who enter and leave high-ranking public positions in the National Executive Branch.

The Anti-Corruption Office approved the MAPPAP pursuant to Resolution No. 7/22. The system was designed by the OA’s Transparency Policy Planning Directorate, in a joint effort with the Department of Technological Innovation of the Public Sector of the Chief of Cabinet of Ministers. It considers citizen control and active transparency mechanisms.

The MAPPAP aims to collate and verify compliance with public ethics standards of people who enter and leave high-ranking public positions in the National Executive Branch. As expressed by the OA, what is sought is to mitigate the risk generated by the entry and exit of high public positions from and to private parties since this implies risks of capturing the public decision that can harm public interest for the benefit of private interests of specific private individuals through the transfer of privileged information, or the lack of impartiality and independence of judgment, among other conduct contrary to public ethics.

As a background, article 12 of Law 25,188 (Law of Ethics in Public Function) already establishes the duty to declare work history in order to control conflicts of interest. For its part, article 45 of the Code of Ethics for Public Functions (Decree No. 41/99) establishes a similar duty to declare positions and functions, public and private, performed after the public function.

The OA expressed in the considerations of the resolution that the system is carried out in order to collect complete information on interests in labor and professional trajectories of those who enter and graduate from high positions of the National Executive Power. In this sense, the MAPPAP is presented as an adequate tool to guarantee compliance by such individuals with the duties imposed by articles 12 of Law 25,188 and 45 of the Code of Ethics of the Public Function.

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Fernando Goldaracena is a partner in Baker McKenzie Buenos Aires Office. He heads the White Collar Crime Practice Group and is a member of the Compliance & Investigations Practice Group. Prior to joining the Firm, Fernando served as secretary of the Federal Criminal Court No. 2 of San Isidro, where he led several criminal investigations ranging from white collar crimes, public corruption and tax fraud. He is member of both the Compliance & Money Laundering and the Criminal Law Practice Groups of the City of Buenos Aires Bar Association (Colegio de Abogados de la Ciudad de Buenos Aires).


Nicolás Servente is an Associate in Baker McKenzie Buenos Aires office.


Candela Perri is an Associate in Baker McKenzie Buenos Aires office.

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