The operation of the F&P Regime, including the F&P gatekeeper function and the systems in place to support the F&P Regime, will remain substantially unchanged. While the F&P Standards are relevant to assessing individuals prior to their appointment (and on an ongoing basis while performing the controlled function), the Conduct Standards only apply once the individual is in the role.
The IAF also introduces a number of enhancements to the F&P Regime to, amongst other things, strengthen the onus on firms and holding companies to proactively certify that individuals in controlled functions are fit and proper on an ongoing basis, and to address some current limitations of the F&P investigative function.