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Compliance Program Update . Russell Guthrie Chief Financial Officer Executive Director, Professional Relations. Evolution of the IFAC Member Compliance Program At a glance. Evolution of the IFAC Member Compliance Program. 2001-2003. Enron Arthur Andersen Sarbanes-Oxley IFAC Reforms.

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compliance program update

Compliance Program Update

Russell GuthrieChief Financial OfficerExecutive Director, Professional Relations

evolution of the ifac member compliance program
Evolution of the IFAC Member Compliance Program2001-2003
  • Enron
  • Arthur Andersen
  • Sarbanes-Oxley
  • IFAC Reforms
evolution of the ifac member compliance program1
Evolution of the IFAC Member Compliance Program2004
  • IFAC Member Compliance Program (CP)
  • Statements of Membership Obligations (SMO) and IFAC admission criteria as global benchmark
evolution of the ifac member compliance program2
Evolution of the IFAC Member Compliance Program2005-2007
  • Self-assessments
  • Transparency – publication on IFAC website
  • Public Interest Oversight Board commences observation of Compliance Program as a public interest activity
evolution of the ifac member compliance program3
Evolution of the IFAC Member Compliance Program2007-2014
  • SMO Action Plans for continuous improvement
  • Monitoring of progress
  • Revised SMOs
  • G-20 adoption status reports
observations on the iesba code adoption
Observations on the IESBA Code adoption
  • Tension between “adoption” (ISAs, IFRSs, IPSASs, IESs) and “adoption of no less stringent requirements” (IESBA Code)
    • IESBA’s different wording for the SMO authoritative statement seems less conducive for PAOs to adopt the “book” of the Code
    • The Code addressed to IFAC Member Bodies sometimes seen by other stakeholders as not their matter of interest
    • Lack of clear understanding of what it means to adopt the Code (IAASB has its Modifications Policy…)
observations on the iesba code adoption1
Observations on the IESBA Code adoption
  • More complex assessment of the adoption of the Code:
    • Aspects embedded in laws, PAO bylaws, sector specific regulatory requirements (banking, stock exchange, insurance, etc.)
    • Adoption not only national but also via Forum of Firms
    • ISAs or IFRSs tend to be adopted “en block”
    • Translation, culture and awareness building (both members and external stakeholders) also an issue
observations on the iesba code implementation
Observations on the IESBA Code implementation
  • Assessing quality of implementation is even more complex
    • What process really exist and operate in practice (as opposed to on paper)
    • Challenges in implementing ongoing supporting activities (I&D, CPD, etc.)
    • Proxy observations are used (effectiveness of I&D process, cases heard, online ethics resources for members, etc.)
evolution of the ifac member compliance program5
Evolution of the IFAC Member Compliance Program2015 & Beyond
  • M&E methodology
  • Dashboard Reports on adoption status & SMO fulfillment
  • Guidance enabling enhanced self-assessment
  • Compliance Program 2.0
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