An important publication that did not get sufficient attention at the time it was published in March 2024 was the Professional Standards Board Annual Report (PSD) for 2023 from the Chartered Accountants Ireland. The publication explained the following:

In 2023 the summary of the quality reviews carried out had the following results:

Quality Review Type Quality Reviews Completed in Year  

 

Satisfactory

 

 

Not Satisfactory

 

Percentage unsatisfactory

Audit 116 87 29 25%
Practice Monitoring 7 6 1 14%
Investment Business 14 14 0 0
AML UK 34 27 7 21%
AML ROI 47 44 3 6%
Insolvency GB/NI 4 4 0 0
Insolvency ROI 9 9 0 0

Overall, one in four of the audit quality review outcomes in 2023 were unsatisfactory. The most notable fact is that generally, the firms that fall into this 84% successful category are those who arrange for annual compliance reviews and always have on hand an up-to-date gap analysis of where they stand in relation to quality management and the implementation of cold file reviews.

Quality review outcomes are considered by the Quality Assurance Committee (QAC) (with the exception of UK insolvency quality reviews which are considered by the Insolvency Licensing Committee). Where quality review outcomes are not satisfactory QAC may impose conditions or restrictions on an individual or a firm (or both). Other options can include a range of measures including:

  • Monetary fine by way of regulatory penalty;
  • Enhanced monitoring via certain regulatory restrictions;
  • Licensing conditions imposed by the QAC;
  • Quality reviews being repeated more frequently than the required statutory visit cycle; and
  • Ongoing outreach (through the PSD Regulatory Bulletin, participation in CPD courses) to all firms providing current information on regulatory matters and common compliance issues.

In extreme cases, QAC may even withdraw a particular licence, registration, or authorisation, (subject, of course, to fair procedure and due process being observed).

Inspections will continue into 2024. It is in every firm’s best interest to avoid receiving an unsatisfactory review. Firms that carry out annual compliance reviews generally get better results on their inspections, so a firm would do well to implement this practice. Your annual compliance review is your firm’s equivalent of an athlete training at the gym to get the best results when they are most needed.

For more on the whole audit quality management (ISQM) process please see our ISQM 1 Toolkit here.

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