How To Tackle Your Resource Pressures with Interim PCF support

Regulations governing financial services companies in Ireland are ever-changing, which puts more pressure on firms’ already stretched compliance teams. More firms are therefore looking outside their organisation for expertise to carry out Interim Pre-Approved Control Function (PCF) roles.


This means bringing in an individual who provides temporary professional support to the company’s compliance operations. In this blog, we look at the benefits of compliance outsourcing and identify the areas that can be filled by an Interim PCF role.


What can an Interim PCF do?

In Ireland, the holders of 54 positions in regulated firms must be pre-approved by the regulator to ensure their “fitness and probity”. Interim PCF roles are being used by both fintech start-ups and established financial services companies’ compliance teams. They can fulfil a wide range of these functions which are specified by Ireland’s Central Bank, including:

  • PCF-12: Head of Compliance.
  • PCF-13: Internal Audit Officer.
  • PCF-14: Chief Risk Officer.
  • PCF-52: Head of Anti-Money Laundering and Counter Terrorist Financing Compliance. (Please note any individual holding the in-situ PCF-15, Head of Compliance with responsibility for AML and CFT designation, are required to notify the Central Bank of the appropriate PCF designation(s) of the individual i.e. either or both PCF-12 and PCF-52 from 3 June 2022.)


Interim roles have grown in importance during the last two years. The Central Bank released guidance during the pandemic that “if a PCF role holder is unable to perform their role due to illness or if a firm cannot fill a permanent PCF role vacancy due to COVID-19, the firm can seek to have another suitable individual perform that role for a limited period”. Firms must seek the approval of the Central Bank for these roles, so it helps if the interim candidate already has a proven track record in regulatory compliance.


Three benefits of interim compliance roles

  1. Fill resource gaps: Whether because of the growing demand for compliance experts due to “The Great Resignation” or competitive recruitment market, interim compliance solutions can support critical functions like regulatory compliance, auditing and risk assessment. Bringing in recognised experts who have been approved by the regulator previously can save companies time and effort.


  1. Reduce risk: Resource gaps in the areas of compliance, auditing and risk expose a company to serious legal and reputational risk. Money launderers and terrorist financers will target companies whose compliance controls are weaker, and regulators will crack down on under-performing compliance regimes. Bringing in an expert Interim PCF limits this risk and ensures compliance remains strong until a permanent solution is found.


  1. Expertise: Interim PCFs are deep domain experts with a detailed understanding of financial services firms’ business models, the industry as a whole, the requirements of regulatory compliance and the regulator’s approach to AML and CFT. Interim PCFs who are part of a consultancy can also draw on a full support team of subject matter experts in other areas – for example, PCFs from fscom work closely with our colleagues who specialise in cyber security.



Contact us today

fscom provides the expertise and resource you need to fill Interim PCF roles. If you are looking for highly-qualified compliance experts to implement a one-off large remediation project or a temporary replacement of a member of your team, contact us today for a free confidential consultation.


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