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Compliance Program Update

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

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  1. Compliance Program Update Russell GuthrieChief Financial OfficerExecutive Director, Professional Relations

  2. Evolution of the IFAC Member Compliance ProgramAt a glance

  3. Evolution of the IFAC Member Compliance Program 2001-2003 • Enron • Arthur Andersen • Sarbanes-Oxley • IFAC Reforms

  4. 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

  5. Holistic approach considerations Level of development and capacity

  6. Holistic approach considerations Other environmental factors

  7. 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

  8. 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

  9. 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…)

  10. 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

  11. 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.)

  12. Evolution of the IFAC Member Compliance Program Reporting on the status of adoption & SMO fulfillment Status of Adoption Status of SMO Fulfillment

  13. 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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