El control de las reglas de prevención de delitos en los sistemas chileno, peruano y argentino ¿En la órbita del compliance officer estadounidense o del organismo di vigilancia italiano?

This work aims at analysing the main differences in the control mechanisms on the preventive models (compliance programs) in three South American legal systems where criminal or administrative liability systems have been incorporated for legal persons. These legal systems are the Chilean, Peruvian and Argentine, and they have been selected since they recognize systems of attribution of ‘ex crimine’ liability to legal entities based on the ‘organizational failure’, thus also respecting the principle of culpability in force in criminal matters. In this way, the idea is to analyse the control systems on the preventive models, in the light of the two main mechanisms created in comparative law, that is, the North American ‘compliance officer’ and the Italian ‘supervisory body’, in order to understand if there has been an inspiration in the models just mentioned, either purely or in a combined way, or if, instead, autonomous figures with their own characteristics have been created by the national legislators