Compliance Note : Amendments to the list of Pre- Approved Controlled Functions (PCFs)

Wed Apr 27 2022

As previously advised, the Central Bank issued a Notice of Intention in September 2021, in respect of amending the list of Pre-Approved Controlled Functions. Links to the Feedback Statement and the Amending Regulations are attached.

The Central Bank has confirmed that they are:

  • Splitting the existing PCF-2 Non-executive director into PCF-2A Non-executive director and PCF2-B Independent non-executive director;
  • Removing the existing PCF-15 Head of Compliance with responsibility for Anti-Money Laundering and Counter Terrorist Financing Legislation and introducing PCF-52 Head of Anti-Money Laundering and Counter Terrorist Financing Compliance;
  • Amending the titles of the roles which relate to the chairing of a board or committee i.e. PCF-3 – PCF-7;
  • Expanding PCF-16 Branch Manager of branches in other EEA countries to include branch managers in non-EEA countries;
  • Removing PCF-31 Head of Investment.

Action required for members

Segregation of PCF-2

All individuals currently occupying PCF-2 will be redesignated as PCF-2A (Non-executive director). It is not a requirement that firms have an Independent non-executive director (PCF-2B), therefore, only where applicable, firms are required to submit confirmation via in-situ process (via the Online Returns system – which should be available by end of this week) of any PCF-2B designations to the Central Bank by 3 June 2022        .

 Segregation of PCF-15/Introduction of PCF-52

The Central Bank advises that this amendment does not, in and of itself, result in any additional or changed requirements regarding the appointment of separate individuals to PCF-12 (Head of Compliance) and PCF-52(Head of Anti-Money Laundering and Counter Terrorist Financing Compliance).   Firms are required to review its functions to determine whether the role meets the substance of PCF-52.  It advises that it is possible that a regulated firm may not require a specific PCF-52. It is also confirmed that Individuals can occupy more than one PCF role e.g., an individual could be listed as PCF-12 and PCF-52.

  • There is no action required from firms where an individual holds an existing PCF-12 designation.
  • With respect to in-situ PCF-15s, this designation will be end-dated, and firms are required to notify (via the online reporting system in-situ return) the Central Bank of the appropriate PCF designation(s) of the individual i.e. either or both PCF-12 and PCF-52 by 3 June 2022.  The in-situ process that will be available to firms for all individuals who were performing these roles prior to 5th April.

If you have any queries on the above, please email

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