Promoting a culture of good governance and greater individual accountability across the regulated financial services sector are core objectives of the Central Bank's proposed individual accountability framework (
IAF) including the senior executive accountability regime (
SEAR).
William Fry's experienced multi-disciplinary IAF/SEAR team is helping clients to prepare for and implement IAF and SEAR. Our team includes specialists in financial regulation, litigation and regulatory enforcement, employment, banking and finance, asset management and investment funds, (re)insurance and fintech.
How we can help
We have vast experience in guiding regulated firms and senior executives in regulated firms through the most challenging regulatory implementation projects. We work with all stakeholders, including the Central Bank, through all stages of our clients' regulatory lifecycle. We also have extensive experience of representing regulated firms and individuals in Central Bank investigations, inquiries and regulatory enforcement action, including the administrative sanctions procedure (ASP).
We can help with:
- Training on the four pillars of the IAF including conduct standards for individuals and regulated firms, fitness and probity reforms, SEAR and individual enforcement reforms.
- Preparing statements of responsibility and responsibility maps by firms which fall within the scope of SEAR.
- Preparing for the fitness and probity certification process.
- Reviewing employment agreements and HR policies and procedures to take account of IAF and SEAR.
- Advising senior executives and individuals in regulated firms on conduct standards for individuals, the duty of responsibility and SEAR.
Follow any of the links below to listen to our podcast series Preparing for Individual Accountability.
Ep1 Background and Introduction to the Individual Accountability Framework
Ep 2 Conduct Standards of the Individual Accountability Framework
Ep 3 Enhanced Fitness and Probity Regime
Ep 4 Senior Executive Accountability (SEAR)
Ep 5 Enforcement Reforms & Wrap Up
On 9 March 2023, the President of Ireland signed the Central Bank (Individual Accountability Framework) Act 2023 into law. Read our full briefing here.
Key features of the Central Bank (Individual Accountability Framework) Bill 2022 published on 28 July 2022, as against the heads of bill published on 27 July 2021. Read our full briefing here.
Preparing for the first pillar of the individual accountability framework - conduct standards. Read our full briefing here.
Preparing for the second pillar of the individual accountability framework - fitness and probity reforms. Read our full briefing here.
Preparing for the third pillar of the individual accountability framework - senior executive accountability regime (SEAR). Read our full briefing here.
Preparing for the fourth pillar of the individual accountability framework - enforcement reforms. Read our full briefing here.
Overview of the individual accountability framework as set out in the heads of bill. Read our full briefing here.
The Central Bank of Ireland proposes greater accountability of senior individuals in regulated financial service providers. Read our full briefing here.