On 28 May 2024, the National Anti-Corruption Mechanism (MENAC) issued Recommendation 7/2024, addressed to entities covered by the General Regime for Corruption Prevention (RGPC), under which the President of MENAC recommends obliged entities that, through their compliance officer, report to MENAC on a monthly basis whether the compliance plan has been regularly complied with or whether there have been any failures or irregularities, identifying them if so. This communication shall take place during the first week of the month following the month to which it relates.
The recommendation came into force at the beginning of June 2024 and was issued under the powers attributed to MENAC by Decree-Law 109-E/2021 of 9 December, in particular the functions of guaranteeing the effectiveness of policies for preventing corruption and for supervising and controlling the plans for compliance with the law, implemented by the obliged entities.
Notwithstanding the importance of this recommendation, we note that no penalty is expressly set forth for non-compliance.
