While the key components of the IAF have been communicated for some time, it is acknowledged that firms and holding companies will need time to prepare for and implement the various elements of the IAF, as applicable, in view of the Central Bank (Individual Accountability Framework) Act 2023 and the related draft Regulations as well as the contents of this Consultation Paper and its associated Feedback Statement, and the IAF Guidance.
It is critical that the initial and ongoing implementation of this framework is not approached as a compliance exercise but rather that it is internalised throughout firms' culture, approach and practices to ensure its successful and sustainable adoption.
Cognisant of the lessons learned from other jurisdictions' experience of the implementation of similar frameworks, clear benefits have been observed from firms' considered implementation in embracing the both the spirit of the framework and what it is seeking to achieve - for the firms themselves in term
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