The Challenges of Implementation
The key challenges of the initial implementation of the IAF will be ensuring;
Your Firm has the buy-in and engagement of senior management, that set the right tone from the top; and
Your Firm designs and implements fit for purpose documents, systems and controls. Some of the key considerations and enhancements that will be required are:
A Management Responsibilities Map (SEAR specific)
– Which must outline the firm’s governance structure, responsibilities and reporting lines of committees and senior management.
Prescribed Responsibilities and Statements of Responsibilities (SoR) (SEAR specific)
– Each firm will be obliged to allocate prescribed responsibilities to Pre-Approved Control Function (PCF), to be documented within each PCF’s SoR.
Certification of CFs and PCFs
– Firms will need to review their existing F&P frameworks to assess if enhancements are required to facilitate the completion of periodic due diligence of staff, to confirm staff remain fit and proper to continue in their role.
Enhanced Corporate and employee documentation
– Firms will need to enhance and/or develop specific policies and procedures relating to their IAF, employee contracts, job descriptions and performance management process (including the incorporation of conduct standards).
Training
– Each firm will need to ensure all impacted staff receive relevant appropriate training on the firm’s IAF.