Lawyers at DLA Piper say that financial firms should begin preparing for the implementation of the changes that will flow from a new bill on individual accountability in the sector.
This follows the recent publication of the Central Bank (Individual Accountability Framework) Bill 2022, after an Oireachtas committee considered the general scheme of the bill earlier this year.
In a note on the firm’s website, DLA Piper’s Brian Hunt writes that, while the bill largely reflects the general scheme published last year, there are also a number of “additional and substantive changes”.
These include enhancements to the fitness-and-probity regime, and changes to the administrative-sanctions procedure.
Central Bank guidance
“Board members and senior management within firms ought to be considering what changes are needed to systems, controls and processes in order to ensure that their firm, and they as individuals, are adequately prepared, and are well positioned to discharge their responsibilities under the legislation,” writes Hunt.
The lawyer does not expect the new regime to be implemented before the second half of 2023, adding that the speed of implementation will be “wholly dependent” on the level of priority given to it by the Government.
He points out that Central Bank regulations will supplement and expand on the bill’s provisions – including in key areas such as the requirement for firms to prepare management-responsibility maps and statements of responsibility.
Hunt writes that the Central Bank is expected to publish the necessary draft regulations and guidance “relatively quickly” after the bill is enacted.