Money Laundering and Audit Implications
Money Laundering and Audit Implications
Table of Contents
PART A............................................................................................................................................................................................3
2 Money Laundering.............................................................................................................................................................4
3 Laws and Regulations.......................................................................................................................................................7
PART B..........................................................................................................................................................................................9
1 Code of Ethics for Professional Accountants...............................................................................................................10
2 Fraud and Error....................................................................................................................................................................15
3 Professional Liability.......................................................................................................................................................18
PART C........................................................................................................................................................................................21
1 Quality Management (firm-wide)...................................................................................................................................22
2 Advertising, Tendering, and Obtaining Professional Work and Fees.......................................................................26
ADVERTISING.....................................................................................................................................................................26
TENDERING........................................................................................................................................................................27
3 Professional Appointments............................................................................................................................................31
PART D.......................................................................................................................................................................................33
1 Business Risk....................................................................................................................................................................34
2 Audit Risks........................................................................................................................................................................35
3 Evidence............................................................................................................................................................................36
4 Audit Procedures.............................................................................................................................................................37
5 Using Work of Others......................................................................................................................................................38
6 Group Audits.....................................................................................................................................................................39
PART E........................................................................................................................................................................................40
1 Subsequent Events..........................................................................................................................................................41
GOING CONCERN.............................................................................................................................................................41
AUDIT EVIDENCE.............................................................................................................................................................43
2 Completion and Final Review.........................................................................................................................................46
3 Auditor’s Report...............................................................................................................................................................47
4 Reports to Those Charged with Governance (TCWG) and Management.................................................................48
PART F........................................................................................................................................................................................49
1 Audit-related and Assurance Services..........................................................................................................................50
2 Specific Assignments.......................................................................................................................................................51
Review of Prospective Financial Information.............................................................................................................51
Due Diligence Review....................................................................................................................................................51
Forensic Service.............................................................................................................................................................51
3 Audit of Social, Environment, and Integrated Reporting...........................................................................................52
4 Audit of Performance Information in the Public Sector.............................................................................................53
5 Reporting on Other Assignments..................................................................................................................................54
EXAM TIPS...................................................................................................................................................................................55
PART A
Regulatory
Environment
2 Money Laundering
Definition
=> process by which criminals attempt to conceal the true origin and
ownership of the proceeds of their criminal activity
=> include: possessing or concealing the proceeds of any crime + failure
by an individual to inform the NCIS or MLRO of knowledge or suspicion
that another person is engaged in money laundering
Step 2: Layering
This is the creation of 'layers' of transactions which seek to disguise the
original origin of the placed cash. In practice this can be so complex that
the cash is almost impossible to trace.
[complex transactions to hamper tracing the cash such as transfer
overseas]
Step 3: Integration
This is the integration of the money back into the legitimate economy, so
that the criminals can use it to make purchases or investments.
[investing or spending cash to place it into the legitimate economy]
If the amount is clearly highly material, it is possible that the firm may
seek to withdraw from the engagement. However, there is a risk that this
could be construed as ‘tipping off’ if money launderer thinks it is because
the audit firm has suspicions over money laundering. The firm should
obtain advice from its legal counsel.
2) The firm ought to establish and maintain proper record keeping system
that contain evidence of client involvement in money laundering as this
will be used by the authority to prosecute the client. In the meantime,
there must be a proper recording of the outcome of the client accepting
procedure to prove that such an activity is being carried out that no
indication client involvement in money laundering.
4) The audit senior should report such situation to the firm’s MLRO. The
MLRO is the internal person (senior position) responsible for receiving and
evaluating reports of suspected money laundering, and for making any
reports to external bodies.
** include the name of the suspect, the amounts involved, the reasons for
suspicion and the whereabouts of any laundered money / made as soon as
possible - an offence to not report suspicions
Audit procedures
Auditing standard requires that the auditor should obtain an
understanding of the legal and regulatory framework in which CLIENT
operates. Therefore, the auditors should obtain a full knowledge and
understanding of the laws and regulations relevant to (case study),
focusing on (what regulations?) and the implications of NOCLAR.
The auditor should request that those charged with governance make any
necessary disclosure to the relevant authorities, clearly state the reasons
why CLIENT should make the disclosure and that if the board fails to
comply, that FIRM will be compelled to make the disclosure themselves.
> If the management does not report to relevant authority or fail to make
the necessary disclosures to parties outside CLIENT, then the auditor
should consider whether they should make the disclosure which depends
on whether there is legal duty to disclose if related to public interest.
+ should obtain a written representation regarding the reason for the non-
disclosure.
Throughout the audit process, the auditor should remain vigilant for signs
of non-compliance or suspected non-compliance that might emerge from
regular audit procedures. These could be discovered through other areas
of testing or discussions with management.
Familiarity 1) Close relationship 1) Both hold higher positions that 1) 1 Remove and replace auditor
could influence the outcome of audit
(occur when, 2) Long association / and place family relationship above 2) 1 Rotated off for two years of
because of a EQCR is a former AP the need of users of financial cooling period after 7 years (AP) / 2 to
close statements 3 years (ATM)
relationship, 2 Appoint an alternative AP (AP) /
members 2) AP is more favourable to CLIENT AP should not serve as EQCR for 2
become too which will be reluctant to issue a years or involve in audit engagement
sympathetic to modified opinion and lack professional 2 Arrange regular independent
the interests of scepticism reviewer for audit engagement (ATM)
others)
Advocacy Representing CLIENT; FIRM may be seen publicly supporting Not allowed by ACEC due to likelihood
Acting on behalf of CLIENT which not seen as having of arising material impact on financial
CLIENT; independence in appearance and statements.
Promoting CLIENT independence of mind to view
financial statements / be less likely to Decline invitation politely as it
* include 3 party
rd
challenge the figures included represents too great threats to
independence
Conflict of Interest 1 Notify both CLIENTs (potential and existing) and obtain consent
2 Advise both clients to seek additional independent advice
- Auditing two CLIENTS in the same 2 Establish Chinese Walls by separating team with different AP and ATM
industry which are rivals at the same 3 ATM need to sign confidentiality agreement
time. 5 Regular monitoring of the application safeguards by an independent senior
individual in FIRM not involved in either audit
Intimidation 1)Removal/litigation FIRM may feel under pressure to cut 1) 1 Inform AC
threat/ fees pressure corners / not raise issues in order to 2 Consider to withdrawal from
(occur when an (satisfy the deadlines) and then signing the contract
auditor is compromise the objectivity of FIRM
deterred from and quality of the audit performed 2) 1 Discuss with FD to reschedule
acting 2) Short reporting time timing of audit work
objectively due CLIENT’s lack of co-operation with 2 If not possible, inform FD that
to threats, auditors can lead to impose limitations audit needs to comply with ISA and QC
actual or on auditors to perform their work procedures
perceived) 3 Consider resignation if threat
continues
Self-review 1) Provision of NAS 1 Potential acquisition is subsequently 1) 1 Decline if listed (not allowed)
[+ MT] (accounting; design reflected in FS / FIRM may be less 2 Establish Chinese wall (listed) and
controls; corporate likely to challenge the figures included arrange for additional review to be
(occurs when a works) / FIRM may not admit any errors undertaken / Use separate teams and
previous ** Can use contingency discovered partners (unlisted)
judgement fees
needs to be re-
evaluated by 2) If FIRM prepares a tax return, there
members 2 Preparing FS may draw the ATM is no threat.
responsible for 2) Tax services inadvertently into performing If FIRM calculates tax, yes.
that management functions
judgement) 3) 1 Clarify the exact areas that
loaned staff will assist
3) Temporary 2 If directly related to financial
assignment of staff statements, remove audit staff
(Auditor loaned / seconded from audit engagement
seconded to CLIENT)
[MT:Care must be taken not to make
[MT: assume management management decisions]
[MT: FIRM undertaking responsibility, making decisions and
management judgements on behalf of client]
responsibilities]
Self-interest 1) Contingent fees (% of 1) FIRM may feel incentivized to allow 1) 1 Not agree to the proposal
X) incorrect accounting treatments in 2 Declined politely as it is not
(occurs as a * NAS, not allowed if it order to maximise profits allowed by ACEC
result of auditor is significant 3 Communicate to TCG regarding
benefitting from FEE = rate x time spent audit fees is charged based on time
CLIENT in spent, skill and experience of ATM
financial and
non-financial 2) FIRM may not be objective and lack 2) 1 Review the terms of the loan. If
way) 2) Loan from CLIENT professional scepticism not, no further action.
(bank) 2 If preferential, either term
amended or remove ATM
3) FIRM may seem making a loan to 3) 1 Discuss with TCG for reasons of
CLIENT which is prohibited by non-payment
3) Overdue fees ACEC / may feel pressure to agree on 2 Request for immediate settlement
(perceived as ’loan’ to certain accounting adjustments in / agree on payment schedule
CLIENT order to have the last year and current 3 Start audit work only once
year’s audit fee paid overdue fees paid
However, the overseas office also read the minutes of the board meetings
to identify issues relevant to the audit. This will involve judgemental from
the auditors which require specialise knowledge. Therefore, the offshore
office may not be competence to perform such service which can effect on
audit engagement of Wire.
The audit firm should have an independent quality reviewer to review the
work performed by the offshore auditors to ensure its reliability. This will
ensure consistency and adherence to local audit standards.
2 Fraud and Error
EXAM APPROACH
Characteristics
=> fraud (intentional) / error (unintentional)
Auditor’s Responsibility
Detecting fraud is the primary responsibility of management, not the
auditor. However,
the matter is complicated because the auditor is required to give
reasonable assurance
that the financial statements are not materially misstated as a result of
fraud (or error).
Moreover, auditors are required by auditing standard to identify and
assess the risks of material misstatements due to fraud. This means that
the audit conducted in line with ISAs should obtain evidence specifically in
relation to fraud.
Audit Procedures
Responsive Risk Assessment
Test the appropriateness of journal Inquiries with management to
entries recorded in the general assess management’s views on
ledger and other adjustments fraud risks and understand
made in the preparation of the management's processes for
financial statements. identifying and responding to
fraud.
Review accounting estimates for Assess how governance oversees
biases and evaluate whether the management’s fraud risk
circumstances producing the bias, processes and controls.
if any, represent a risk of material
misstatement due to fraud.
For significant transactions that are Evaluate any unusual relationships
outside the normal course of in data, especially in revenue
business for the entity, or that accounts, for potential fraud
otherwise appear to be unusual indicators.
given the auditor’s understanding
of the entity and its environment **inconsistency between current
and other information obtained year with previous year or budget
during the audit, the auditor shall or industry average’s result
evaluate whether the business ** inconsistency between client’s
rationale (or the lack thereof) of results and auditor’s expectations
the transactions suggests that they in the context of knowledge
may have been entered into to
engage in fraudulent financial
reporting or to conceal
misappropriation of assets.
Evaluate whether the outcomes of Identify conditions that allow fraud:
analytical procedures are incentive, opportunity, and
consistent with the auditor’s rationalization.
understanding of the entity, or 1) incentive or pressure 2)
they indicate risk of material perceived opportunity 3) ability to
misstatement due to fraud. rationalise
The auditor shall obtain written Identify areas susceptible to
representations from management material misstatement due to
and, where appropriate, those fraud, setting aside any
charged with governance that assumptions of integrity about
they: management.
Auditor’s Responsibilities
Detecting fraud is the primary responsibility of management, not the
auditor. However,
the matter is complicated because the auditor is required to give
reasonable assurance
that the financial statements are not materially misstated as a result of
fraud (or error).
Moreover, auditors are required by auditing standard to identify and
assess the risks of material misstatements due to fraud. This means that
the audit conducted in line with ISAs should obtain evidence specifically in
relation to fraud.
The audit process is, however, subject to inherent limitations which are
particularly relevant to the problem of fraud. Fraud may involve
sophisticated attempts at management which makes the auditor's
task even more difficult. It is therefore quite
possible for the auditor to have conducted an audit in accordance with
ISAs, but still have failed to detect a material misstatement resulting from
fraud.
Conduct of audit
Professional scepticism is a key weapon in the auditor's attempt to detect
misstatements resulting from fraud. The audit of CLIENT does not appear
to have been conducted with an attitude of professional scepticism,
possibly as a result of it being a long-standing audit.
Expectation Gap
=> refers to the deviation between client’s expectations of auditor’s
duties and the auditors’ actual duties
ETHICAL REQUIREMENT
HUMAN RESOURCES
Junior assigned difficult audit work (areas which require Junior should not be assigned such audit works –
specialised skills and experienced) – unlikely to have allocate to more senior and experienced which needed
developed the judgement needed to audit these areas skills to perform – otherwise, pairing system to offer
additional guidance
Junior helped out with inventory count - lack of Auditor should instead have been observing that the
understanding/supervision client’s staff were counting them correctly and
accordingly
ENGAGEMENT PERFORMANCE
Use of judgement for sampling – increases sampling Instead of relying solely on judgment, auditors should
risk – some items excluded from sample, so sample use statistical sampling methods such as random
cannot be representative of population sampling, systematic sampling, or stratified sampling,
which help in selecting samples that are more
representative of the entire population. These
techniques provide a quantifiable measure of sampling
risk and help auditors make more accurate
generalizations about the population.
Changed item selected in sample – inappropriate to
pressure – increases detection risk led to wrong opinion Sample sizes detailed in audit plan should have been
/ Changed sample size - inappropriate response to time signed to gather SAAE / Audit time budgets should
pressure allow staff enough time to complete the audit
Insufficient audit evidence obtained in relation to The auditor should communicate with management to
(issue) – possible limitation on scope imposed by understand the reasons for the imposed limitation and
management and discuss the importance of allowing access to the
intimidation threat necessary information. This conversation could help
resolve misunderstandings or reveal if the limitation is
intentional, potentially indicating a broader issue.
Other services
A description of any other services FIRM can offer, such as offering advice
in relation to the proposed stock exchange listing. Careful consideration
should be given to ethical requirements relating to independence when
offering other services to a potential audit client.
Key staff
Details of the proposed engagement partner and of his experience that is
relevant to this audit. Details should also be given of the approximate size
and composition of the audit team, together with a description of the
relevant experience of key members of that team.
Timing
Details should be provided of the timeframe envisaged for the various
aspects of the audit. This might include details of when the subsidiaries
would be audited, when the consolidation process would be audited, and
an estimate of by when the group audit opinion could be completed.
Fees
The proposed fee should be included, along with an explanation of how it
is calculated. This would include details of the charge-out rates of the staff
likely to be used on the audit, along with estimates of the amount of time
the audit would be likely to take.
Advantages Disadvantages
1) Reduction in external audit costs 1) Loss of long-term relationship
– ultimately increase the returns to with the auditors:
shareholders - incumbent auditor not being
reappointed if rate quoted by
former auditor not the most
competitive
- frequent change in auditor may
not be favourable as new
relationship takes time to be
established
2) More efficient auditing can be 2) High first year audit cost – new
expected auditor spending substantial time
to familiarise with CLIENT’s
business and the accounting
system (expect additional time to
be spent)
3) Greater reliance on computer 3) Loss of trust from stakeholders –
assisted audit techniques CAATs – the change of auditor as client
improve audit efficiency – can having disputed with previous
counter the low audit fee auditor – indication of poor
relationship
Resources
An auditor may find that it lacks the resources to carry out an audit,
perhaps because the client has grown rapidly so that the firm lacks the
staff to provide a big enough audit team.
Competence
An auditor might believe itself not to be competent enough to carry out
the audit, perhaps because the client operates in an industry with highly
specialised accounting requirements, in respect of which the firm lacks the
necessary expertise.
1) Its competence to perform the engagement and whether the firm has
the capabilities, including time and resources to do so
Contents of a Proposal
1) Nature, Purpose, and Legal Definition of Audit:
Clarify the legal responsibilities of management under the Companies Act.
Define the auditor's roles in a statutory audit to establish a clear
understanding and minimize any expectation gap.
=> only if CLIENT is never being audited before
2) Client Expectations:
Clearly outline what the client expects from the audit engagement, as this
framework guides the
=> ensure FIRM understanding and CLIENT expectation are correct
auditor's work.
4) Audit Methodology:
Describe the proposed audit methodology, taking into account existing
internal controls and the specific risks associated with the client’s
business.
=> reflect the controls that exist in the CLIENT
Resources
An auditor may find that it lacks the resources to carry out an audit,
perhaps because the client has grown rapidly so that the firm lacks the
staff to provide a big enough audit team.
Competence
An auditor might believe itself not to be competent enough to carry out
the audit, perhaps because the client operates in an industry with highly
specialised accounting requirements, in respect of which the firm lacks the
necessary expertise.
** Independence
** Conflict of interest
PART D
Planning and
Conducting and
Audit of Historical
Financial
Information
1 Business Risk
EXAM APPROACH [Identify (from PAP and notes in FS) + Implications
(negative -> financial or non-financial data from study case)]
BR translated to ROMM
example: started to stop selling one product – sell new products – revenue
might be affected (BR) (ROMM) affected in inventory balance – failed to
sell products which will reduce the value of inventory – follow IAS 2 –
valued at the lower of cost and NRV
Business strategy
– what they are planning to do
Accounting policies
2 Audit Risks
EXAM APPROACH => ROMM [Identify + Materiality + Standard + Implications on FS]
Standard (IFRS / IAS) Implications on FS
IR - IMSR
CR – related to poor controls (no standard)
DR + definition + why
**
3 Evidence
EXAM APPROACH
4 Audit Procedures
EXAM APPROACH [A E I O U + source of evidence + why]
Inspect – review
compUtation – recalculate /
Component Auditor
6 Group Audits
PART E
Completion, Review and
Reporting
Role: reviewer
Review the AWP fo the team (refer Implications of the matters and
back to QM topic) => pre- impact on audit report (unmodified
issuance or modified – qualified or adverse
or disclaimer)
- whether the team has obtained [Material + Opinion + Types of
SAAE report – M+P?]
- areas / ROMM which are
considered are high risks Material but unresolved =>
Modified (if resolved =>
Matters to be considered: related UNModified)
to accounting matter ~ Qualified (notP) or Adverse (P):
[Identify + Materiality + Standard – related to FS
correct and wrong matter) ~ Qualified (notP) or Disclaimer
(P): unable to obtain SAAE
Evidence expect to find
[Source + why] – no Verb !! ** NotP => relating to one or few
matters
** P => relating to substantial
matters (eg: did not depreciate –
co shows profit)
1 Subsequent Events
GOING CONCERN
Financial statements should be prepared on a going concern basis unless
that basis is inappropriate. As a fundamental principle the going concern
basis is assumed in the absence of information to the contrary. Material
uncertainties which cast significant doubt on the appropriateness of the
going concern basis should be disclosed.
In relatively rare circumstances when the going concern basis is not used,
the financial statements should disclose:
- that fact;
- the basis of preparation (e.g. on a liquidation/break-up basis);
- why the entity is considered not to be a going concern (e.g. if the
company is subject to insolvency proceeding).
Auditor’s Responsibility
The auditor should consider the appropriateness of management's use of
the going concern basis (in preparing the financial statements) when
planning, conducting and evaluating the results of audit procedures. The
auditor must also consider whether material uncertainties relating to the
going concern basis require disclosure.
Management's Responsibility
IAS 1 requires management to assess the entity's ability to continue as a
going concern. (Where a financial reporting framework is not explicit
about management's responsibility, it is implied because going concern is
a fundamental principle.)
Planning Considerations
Events or conditions which may cast doubt on the entity's ability to
continue as a going concern should be considered when planning the
audit.
1) Preliminary Assessment
Management may have already made a preliminary assessment of going
concern issues and plans to address them, for example:
raise capital;
increase borrowings;
restructure debt;
defer capital expenditure;
put research and development projects on hold;
liquidate assets.
3) Mitigating Factors
The auditor should consider factors which mitigate doubts about going
concern, for example:
- Management's plans, which must be feasible, to maintain adequate
cash flows by alternative means: disposal of assets / rescheduling of loan
repayments / obtaining additional capital.
- The availability of a suitable alternative source of finance.
AUDIT EVIDENCE
1) Evaluating Management's Assessment
Management's assessment of going concern should be evaluated for the
same period as required by the financial reporting framework. This should
be extended to 12 months from the end of the reporting period (if
greater).
2) Sources of Information
Sources of information to support management’s assessment include:
Client's system for timely identification of warnings of
risks/uncertainties.
Budgets, forecast information, etc.
Obligations, undertakings, guarantees with lenders, suppliers, etc.
Bank borrowing facilities and suppliers' credit.
Management's plans for future action.
4) Additional Procedures
When there are indicators of significant doubts, the auditor should:
review management's plans for future actions and obtain written
representation thereon;
gather sufficient appropriate evidence to determine whether or not
a material uncertainty exists.
5) Material Uncertainty
A material uncertainty exists when the magnitude of its potential effect is
such that its disclosure is necessary for the fair presentation of the
financial statements (i.e. a lack of disclosure would render the financial
statements misleading).
8) Conclusions
Basic Principle:
The auditor should exercise professional judgement to determine
whether material uncertainty exists.
Disclosure Requirements in the Financial Statements:
Where material uncertainty exists, the notes to the financial statements
must include:
A description of:
o the principal events or conditions raising significant doubt;
o management's plans (including mitigating factors).
A statement that there is material uncertainty:- therefore, the
entity may be unable to realise assets and discharge liabilities in
normal course of business.
A statement that financial statements do not include any
adjustments relating to the recoverability and classification of
recorded asset amounts and liabilities.
Situations
1. Based on the audit evidence obtained there is no material
uncertainty.
2. The going concern basis is appropriate but material uncertainty
exists which is adequately disclosed.
3. As for (2) but adequate disclosure is not made.
4. The going concern basis is inappropriate but the financial
statements have been prepared on a going concern basis.
5. The going concern basis is inappropriate and the financial
statements have been prepared on an alternative basis, which is
adequately disclosed.
6. Management does not make an assessment for a period of at least
12 months from the end of the reporting period when asked to do
so.
Forensic Service
3 Audit of Social, Environment, and
Integrated Reporting
4 Audit of Performance Information in
the Public Sector
5 Reporting on Other Assignments
EXAM TIPS