by John McCarthy Consulting Ltd. | Jun 18, 2024 | Blog, News
Following on from last week’s blog on cold file reviews and ISQM 1, this week we look at the various factors that can cause changes to the monitoring and remediation elements of ISQM 1.
The following variables are usually areas that need updated:
- The quality objectives set out in the system of quality management (SoQM);
- The quality risks of their assessments; and
- The responses to those risks.
Changes in these areas are mainly a result of:
- Changes in the nature and circumstances of the firm and its engagements; and
- Remedial actions to address deficiencies in the system of quality management.
These changes can arise in a variety of ways, such as:
- Changes to quality objectives;
- A need for new additional quality objectives g. if the firm opens a new office, merges with another firm or starts providing a new service;
- Additional quality objectives established by the firm may no longer be needed, or may need to be modified; and
- Root cause analysis (RCA) may identify that previous attempts at fixing issues from past cold file reviews are no longer be needed, need to be modified, or require a new solution.
Remember that the Specified Responses prescribed by the standard (detailed here in paragraph 34) must not be modified or removed, unless one or more of them is no longer relevant to the firm. The firm may decide that it’s appropriate to modify how these Specified Responses are designed and implemented.
The types of changes that can be triggered by the cold file review process broadly fall into two categories:
- Changes to quality risks such as:
- New quality risks are identified;
- Existing quality risks no longer qualify as quality risks;
- Existing quality risks need to be modified; and
- Existing quality risks need to be reassessed.
- Changes to responses to quality risks such as:
- New responses may be designed and put into action;
- Existing responses may be discontinued and deemed no longer appropriate; and
- Existing responses may need to be adjusted for changes in circumstances such as a new audit programme.
For more on the whole ISQM process please see our ISQM 1 Toolkit on our website here.
Please go to our website to see our:
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- AML Webinar (December 2023) available here, which accompanies the AML Manual. It explains the latest legal AML reporting position for accountancy firms and includes a quiz. Upon completion you receive a CPD certificate for attendance in your inbox.
- Letters of engagement and similar templates—Please visit our website here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items bought together.
- ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please contact John McCarthy FCA by email at john@jmcc.ie.
- We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. The ISQM TOOLKIT 2022 is available to purchase here.
by John McCarthy Consulting Ltd. | Jun 10, 2024 | Blog, News
Are cold file reviews necessary? A good question you might say.
One of the main characteristics of ISQM (Ireland) 1 (hereafter ISQM 1) (ISQM1 Updated Oct 2023) is that the standard is iterative, and so it is implemented is by carrying out audits of cold file and hot file reviews. Ideally these reviews are carried out by someone experienced and unconnected with the audit assignment so that the results are fully objective and up to date.
One objective of the reviews is to identify issues that may require amendment in the ISQM so that it is a constantly evolving document.
Per ISQM 1 requirements, the monitoring process must provide a basis for identifying deficiencies in the system of quality management such that prompt remedial action can be taken, and the deficiencies can be communicated to the audit teams without delay.
ISQM 1:38 requires the monitoring process to include the inspection of completed audits (cold file reviews). The cold file reviews must include at least one completed audit from each Responsible Individual on ‘a cyclical basis determined by the firm’.
Bear in mind that the monitoring process does not only involve carrying out cold file reviews. The system of quality management must be generally monitored to achieve the objectives of ISQM 1. These objectives are set out in the question: “What is the purpose of the monitoring and remediation element of ISQM 1?”
For more on the whole ISQM process please see our ISQM 1 Toolkit on our website here.
Please go to our website to see our:
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- AML Webinar (December 2023) available here, which accompanies the AML Manual. It explains the latest legal AML reporting position for accountancy firms and includes a quiz. Upon completion you receive a CPD certificate for attendance in your inbox.
- Letters of engagement and similar templates—Please visit our website here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items bought together.
- ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please contact John McCarthy FCA by email at john@jmcc.ie.
- We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. The ISQM TOOLKIT 2022 is available to purchase here.
by John McCarthy Consulting Ltd. | Mar 2, 2023 | News
The Financial Times reported in late February 2023 on a classic example of CDD (Client Due Diligence) gone wrong, or more likely ‘Careless Due Diligence’.
As part of the required anti-money laundering (AML) checks, before taking their new client in 2021, the London Law firm, Discreet Law, requested identification documents from Yevgeny Prigozhin, who is the founder of the Wagner mercenary group. His name is on the sanctions lists of individuals accused of human rights abuses since 2018.
In response, Mr Prigozhin’s Russian lawyers forwarded a copy of his passport and a gas bill in the name of his then 81 year old mother, Violetta, for an address in St Petersburg, Russia.
Apparently the law firm were happy with the explanation that the bill was issued in the name of the claimant’s mother (Violetta Prigozhin) who actually lives at the client’s residential address and pays the bills. Her name has been added to the list of sanctioned individuals for her support of her mercenary son.
In March 2022, one month after Russia’s full-scale invasion of Ukraine, the firm applied to stop representing him.
The moral of the story is that each firm when carrying out CDD must ‘take reasonable steps’ as set out in Section 33 (5) of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021which includes verifying that the utility bill is correctly in the name of the individual concerned and that the address is their normal residential address.
PS – the above image is a stock photo and not known to resemble Mrs. Prigozhina.
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.
by John McCarthy Consulting Ltd. | Feb 25, 2023 | News
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.
by John McCarthy Consulting Ltd. | Feb 17, 2023 | News
Our blog last week, about Ireland’s Golden Visa programme was quite timely. It dealt with the Government’s controversial scheme to attract overseas investors to Ireland.
On 15 February the Government closed access to Ireland’s so called ‘Golden Visa’ scheme, which in 2022, attracted 1,275 applications from China and 41 from the rest of the world. The official title of the programme is the ‘Immigrant Investor Programme’ (IIP). For AML purposes, such investors must be classified as ‘high-risk’. We understand that applications that had been made prior to 15 February 2023 will still be dealt with on a case-by-case basis.
According to an Irish Times report some of the beneficiaries of the IIP programme included Trinity College Dublin, housing charity iCare, the GAA and Dundrum South Dublin Athletics Club, which alone received €9.36 million in IIP contributions.
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.
