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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 Program

2001-2003

  • Enron

  • Arthur Andersen

  • Sarbanes-Oxley

  • IFAC Reforms


Evolution of the ifac member compliance program1

Evolution of the IFAC Member Compliance Program

2004

  • IFAC Member Compliance Program (CP)

  • Statements of Membership Obligations (SMO) and IFAC admission criteria as global benchmark


Holistic approach considerations

Holistic approach considerations

Level of development and capacity


Holistic approach considerations1

Holistic approach considerations

Other environmental factors


Evolution of the ifac member compliance program2

Evolution of the IFAC Member Compliance Program

2005-2007

  • 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 Program

2007-2014

  • 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 program4

Evolution of the IFAC Member Compliance Program

Reporting on the status of adoption & SMO fulfillment

Status of Adoption

Status of SMO Fulfillment


Evolution of the ifac member compliance program5

Evolution of the IFAC Member Compliance Program

2015 & Beyond

  • M&E methodology

  • Dashboard Reports on adoption status & SMO fulfillment

  • Guidance enabling enhanced self-assessment

  • Compliance Program 2.0


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