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In t e r n a t io n a l F e d e r a t io n o f Ac c o u n t a n t s
Szymon RadziszewiczTechnical Manager, Compliance Program
IFAC
Beirut, 23 April 2009
Action Plans: Challenges and Success Factors
IFAC Compliance Program Workshop for AFAA Members
IFAC Compliance Program
Background and Status
Action Plans – Issues & Challenges
Key Success Factors
Why prepare?
Points for discussion
2
How it all started? 7 Statements of Membership Obligations
Self-Assessment through Parts 1 and 2
Where is it heading? Part 3, Action Plans for continuous improvement
IFAC Compliance Program
Part 3, Action Plans
All IFAC members and associates participate
All 7 Statements of Membership Obligations to be addressed: To achieve compliance
To maintain compliance
Part 3, Action Plans – Current Status
5
Status as of April 22, 2009 All IFAC AFAA
Published Action Plans 32 1
Draft Action Plans received•Complete, partial sections, local language•Review underway by staff and Compliance Advisory Panel
63 3
Working on Action Plans 47 3
Policy Recommendations in process of review 15 2
TOTAL 157 9
Issues – Adoption of ISAs and IFRS
Treated as a “one-time” process
Significant gaps remain (“local adaptation”)
No ongoing mechanism to keep up with
issuance of new standards
Insufficient resources
Translation challenges
6
Issues – Adoption of ISAs and IFRS
Adoption versus implementation
There is a huge difference between adoption
and implementation
Although many countries have formally adopted
IFRS and ISA, many lack the experience, skills,
training and basic tools to put them properly into
practice
7
Issues – Code of Ethics and I&D
Use of outdated Code of Ethics Not using the threats and safeguards framework
Applicability to both auditors AND accountants
in business
Investigation and disciplinary programs Mechanisms developed but no power or sufficient
resource to properly sanction
8
Issues – Quality Assurance and Quality Control
The structure of the program does not conform
with SMO 1, Quality Assurance
QA system may have been established, but: Not implemented
Not sustainable
Based on outdated standards
Quality control standards at the firm and
engagement level have not been mandated Need to adopt ISA 220 and ISQC 1
9
Issues – Education
Need for both academic education and practical
experience Real life experience in accounting and auditing
Applying ethical principles
University syllabus and final examination updates
CPD – number of hours and monitoring
compliance
10
Key Challenges
Lack of financial and technical capacity in many
professional accountancy bodies calls for:
Investment in the accountancy profession by national
governments and donor agencies
Support of regional organizations
More advanced bodies acting as mentors
Development of implementation tools
Ability of bodies to clearly communicate challenges,
required actions, and need for resources will be crucial to
obtain assistance 11
Establish or enhance existing processes to support adoption and implementation of international standards
Continuous updating of education and training programs
Solutions – Action Plan Objectives
Implement or improve external quality assurance programs
Keep watching brief on new and modified standards and regulatory changes and address them in a timely and effective manner
Establish or maintain good relationship with government and regulators
Meaningful actions, clear accountabilities and reasonable timelines
Solutions – Action Plan Objectives
Part 3, Action Plans - Example
Key Success Factors
Taking Ownership of the Action Plan:
Use technical committees to draft the
plan for each SMO
Discuss Action Plan at all levels of
organization’s governance structure
Involve key stakeholders: regulators and
government
Taking iterative approach: Frequent interactions with the Compliance staff Submit drafts / partial drafts for an early review Incorporate Compliance staff’s feedback and
suggestions
Key Success Factors
Key Success Factors
Identify resources needed to make thenecessary changes:
Internal: Staff
Volunteers
External: Funding sources / potential donors
Twinning partners / mentors
Available Supporting Materials
Guidance Notes
Action Plan Template
Published Action Plans
http://www.ifac.org/ComplianceAssessment/published.php
Way Forward
Action Plan is just the first step along the way…
“Evergreen” document that needs to be
continuously updated for future developments
Progress reporting and monitoring
IFAC to facilitate assistance and provide
valuable tools
Cooperation within AFAA – way to success
Important Developments to Address Now
IAASB Clarity Project
Revisions of the Code of Ethics
Need to be reflected in the Action Plan
Why Prepare?
“Participating in the Compliance Program has been truly meaningful and rewarding experience for CICPA, leading to important improvement in major areas of the development of the accounting profession in China.
Especially, the Policy Recommendation and Action Plan process have been very helpful for us to work out the convergence plan, enhance quality assurance program and communicate effectively with regulators and the government.”
China (CICPA)
Why Prepare?
“Completing the Action Plan was a very useful exercise for the CICA as it allowed us to consolidate and summarize in one place all that we were doing to fulfill our IFAC obligations and assists us in demonstrating to all of our stakeholders our strong commitment to quality.
The Action Plan provides us with a useful tool for managing our commitment to SMOs and how we are performing as a member body, and we believe the process will prove equally useful to other IFAC members.”
Kevin Dancey, President and CEO CICA Canada
Why Prepare?
The Action Plan process helped:
“to accelerate our discussions around convergence”
– Brazil
“to organize our goals and steps to achieve them so
they can be clearly seen” – Russia
“in the process of becoming full member of IFAC” –
Romania
“to confirm that the we are heading in the right
direction” – Czech Republic
Points for Discussion
Key Priorities?
Key Challenges?
Relationship with government and regulators?
Standard-Setting: Responsibilities?
Legal Framework?
“Low hanging fruits”?
What can AFAA do to assist?
Turbulent Times – Times of Opportunity
S u c c e s s h a p p e n s w h e n
p r e p a r a t io n
m e e t s
o p p o r t u n it y
In t e r n a t io n a l F e d e r a t io n o f Ac c o u n t a n t s
Beirut, 23 April, 2009
Thank You
Please Visit www.ifac.org/ComplianceProgram
For Further Information