As of 4 June 2022, (under EU sanctions) it is prohibited to provide, directly or indirectly, accounting, auditing, including statutory audit, bookkeeping and tax consulting services, as well as business and management consulting or public relations services (Article 5n of Council Regulation 833/2014) to the Russian government, as well as to legal persons such as companies and other entities or bodies established in Russia.
Trying to assess the implications of the increasingly complex and varied sanctions regimes imposed on Russia (and on certain other countries/individuals and entities around the world) is already a huge headache. Some would say it’s not worth the effort. The compliance cost alone, plus the potential for getting the risk assessment wrong, versus the benefit of taking on a ‘risky’ client is too high.
It’s highly recommended that each firm carry out a complete sweep of all existing clients including those clients’ suppliers/customers (not just with the firm’s new clients) to verify whether there are any connections with Russia or with individuals/entities resident there.
Commencing in March 2022 the Big 4 accounting firms announced their withdrawal from Russia and with the war with Ukraine passing its first anniversary, it doesn’t look like this conflict will be resolved any time soon.
For quick access to the main Sanctions lists, please click on the following links:
Have you sourced all the Supplier Quality Statements you need? In case you ask, here is the one from John McCarthy Consulting Ltd
ISQM Toolkit training
The ISQM TOOLKIT 2022 is self-explanatory and is available to purchase here.
This is the first time for adoption of this new standard and the various professional bodies have already commenced carrying out spot checks on firms and their implementation of this standard.
We are running a series of one to one private Zoom sessions to explain how it all works in a structured 1hour CPD session on Zoom with a free recording.
In addition, there is a half-day follow-up where we go through the actual Toolkit itself in a 4-hour session to document your risks and responses. We can also proof your final toolkit with suggestions for improvements. Contact john@jmcc.ie for more details.
- See our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
- Also we have an updated AML webinar (March 2022) available here, which accompanies the AML Manual. It explains the current legal AML reporting position for accountancy firms and includes a quiz. Upon completion, you receive a CPD Certificate of attendance in your inbox.
- To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
