Transcript Slide 1

International Federation of Accountants
Member Body Compliance Program
Russell Guthrie, Executive Director
IESBA Meeting
New York, USA
October 19, 2011
Member Body Compliance Program
A Brief History
• Program and Compliance Advisory Panel
launched in 2004 as part of IFAC Reforms
• Established 7 Statements of Membership
Obligations (SMOs):
– QA, Education, ISAs, Ethics, IPSASs, I&D, IFRS
• PIOB oversight
Compliance Program Focus
Strategic Considerations
• Supporting continuous improvement of
strong PAOs through SMOs
• Influence PAOs’ agendas and actions
• Information and knowledge sharing
• Collaboration with stakeholders
Compliance Program Focus
Continuous Development and Improvement
• Part 1 – Information Gathering: Overview of
regulatory and standard-setting framework in
a member’s jurisdiction
• Part 2 – Self-assessment: Benchmarking
against the 7 SMOs
• Part 3 – Own Strategy: Action Plans for
development & continuous improvement in
addressing the SMOs
Impact / Achievements
Beginning of the Road
• Action Plans as first step:
– Transparent plans for continuous improvement
(153 out of 163 published)
– Annual updates by all member bodies
– Monitoring of progress by the CAP
• Time and resources needed to achieve
meaningful change
• Outreach activities and policy advice
provided by the IFAC Staff
Impact / Achievements
Enforcement – since 2005
• To date – key focus on commitment to and
participation in the Compliance Program
• Enforcement Actions
– 43 suspension warnings
– 18 suspensions
– 9 expulsion warnings
– 5 expulsions
Uptake of the Code of Ethics
Russia –Drivers of Local Modifications
• Working on adoption of the recent Code
• Adoption environment:
– Ethics Committee of the Audit Council under Min Fin
– Independence rules must eventually be aligned with
Russian legislation
– Initial proposal to start with existing Russian CoE (based
of old and abbreviated version of IESBA Code) and then
make necessary additions
– Auditors and accountants need different Codes
• IFAC Staff providing guidance and analysis to
PAOs, Large Firms, MoF
Uptake of the Code of Ethics
Latin America – Multiple Stakeholders
• Challenges:
– Barriers of legal, institutional, cultural and financial nature
– Lack of ongoing mechanism for adopting and implementing
changes
– Lack of current translation makes it difficult to discuss with
regulators, analyze independence requirements and organize
relevant communications and trainings
– To achieve meaningful change a thorough cultural change is
needed
• IFAC coordinates formation of a Latin America
Review Committee to facilitate translation at
the regional level
Uptake of the Code of Ethics
France – More Stringent Requirements
• Ministry of Justice adopts ethical requirements for
CNCC:
– Requirements for CNCC endorsed by MinJus in consultation with
AMF (securities market regulator), and the H3C
– Requirements are considered to be more stringent than IESBA Code
• CSOEC drafts its ethical requirements to be approved
by Ministry of Economy and Finance
– Direct incorporation of IESBA code impossible due to a different
structure (Ordinance of 1945, OEC bylaws, other doctrinal texts)
• Both French Bodies are planning to promote the
adoption of the recent IESBA CoE to the
Government
Uptake of the Code of Ethics
Malawi – Direct Adoption
• IFAC Member sets the ethical requirements
through a mandate implied by general
consensus
• Adopted IESBA Code of Ethics in 2008
without any modifications
• Issuing the current IESBA CoE with Jan
2012 effective date
• Action Plan focus on implementation support
Uptake of the Code of Ethics
Overarching Themes
• CoE clearly used as a major point of reference
– Strong awareness among PAOs
• Adoption challenges
– Principles and rules at a national level often
embedded in legislation, regulation and member
body governance documents
• Implementation challenges
– Overcoming cultural barriers
Tracking of Adoption – Challenges
Complex National Environments
• Government (MinFin, Ministry of Justice)
• Regulators (Capital Market, Insurance, Banking)
• Professional accountancy organizations
• Cultural differences, even different understanding
of the concept of morality
Tracking of Adoption – Challenges
Differing MB Constituencies
• Auditors:
– Big firms
– SMPs
• Professional Accountants in Business
• Management Accountants
• Public Finance Accountants
• Accounting Technicians
Tracking of Adoption – Challenges
Different than Standards that Tend to be
Adopted en Block
Other Matters of Interest
Moving Forward
• SMO Revisions
– Clarified no best endeavors where PAO has
direct responsibility
– Removed “no less stringent standards”
langauge
• How do we best track and articulate
“adoption” of CoE and/or key independence
provisions
Other Matters of Interest
Moving Forward
• Who is will determine whether local
modifications are substantive (i.e., lead to
different outcomes)?
International Federation
of Accountants
www.ifac.org